Adam Braverman, Brian Michael, Christine Wong, James Koukios, and Will Baker authored an article for the Daily Journal offering guidance on how companies should benchmark communications and compensation policies in response to the revised Evaluation of Corporate Compliance Programs implemented by the Department of Justice (DOJ).
"Fitting into a history of expanded guidance to companies regarding how to assess, design, and enhance their compliance programs, on March 3, the U.S. Department of Justice announced revisions to its Evaluation of Corporate Compliance Programs guidance materials, or ECCP," the authors wrote. "These latest revisions, the first in nearly three years, focus upon compliance controls regarding messaging applications, such as WhatsApp, as well as the interplay between compliance and compensation structures. These revisions reflect DOJ's ongoing efforts to grapple with evidentiary and other challenges posed by messaging apps commonly used worldwide, as well as to incentivize companies to have enforcement mechanisms in place for compliance failures."
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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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