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About the DOJ compliance guidance updates

On June 1, 2020, the DOJ updated its guidance document entitled Evaluation of Corporate Compliance Programs (ECCP).¹ Subsequently, on July 3, 2020, the DOJ and US Securities and Exchange Commission (SEC) issued an updated version of their 2012 “A Resource Guide to the U.S. Foreign Corrupt Practices Act.”² As DOJ and SEC’s expectations continue to evolve in both sophistication and granularity with respect to compliance programs, companies may need to make significant or additional investments to keep up.

Our insights focus on the changes in terms of what’s new, related evolving trends, and how you might adapt your corporate compliance program to meet the expectations contained in the new DOJ compliance guidance.

¹ US Department of Justice, Criminal Division, “Evaluation of Corporate Compliance Programs, Guidance Document,” June 2020 (updated).

https://www.justice.gov/criminal-fraud/page/file/937501/download.

² Department of Justice, Criminal Division, and US Securities and Exchange Commission, “A Resource Guide to the U.S. Foreign Corrupt Practices Act,” Second Edition – July 2020.

https://www.justice.gov/criminal-fraud/file/1292051/download.