A Side-by-Side Look at How the Revised ECCP Compares to the Original

The DOJ recently announced a total revision of its Evaluation of Corporate Compliance Programs (ECCP) guidance including significant changes in the questions prosecutors will ask about a company’s compliance program. To help show exactly what has changed, we have put together a side-by-side comparison of the old and new questions. An analysis of the new narrative guidance and the implications for the edits overall can be found here. See “DOJ’s Guidance Shows That Compliance Programs Still Matter” (Mar. 15, 2017).

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