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ARTICLE · 30 SEPTEMBER 2024

DOJ's Criminal Division Updates Policy On 3 Key Topics: Artificial Intelligence, Whistleblower Programs, And Compliance Program Resources

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute...

United StatesCriminal Law
Laurence Urgenson
Laurence Urgenson
Jason Linder
Jason Linder
Adam S. Hickey
Adam S. Hickey
J. Gregory Deis
J. Gregory Deis
Gina M. Parlovecchio
Gina M. Parlovecchio
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Juliet Gunev
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Glen A. Kopp
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Ravi Shah
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Rose A. Lyn
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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to US Department of Justice (DOJ) policy on Evaluation of Corporate Compliance Programs (ECCP): the use of new technologies such as artificial intelligence (AI), whistleblower programs in practice, and the adequacy of resources for compliance programs to allow continuous monitoring and improvement.

The ECCP is the roadmap used by Criminal Division prosecutors to evaluate a company's compliance program during a criminal investigation. In deciding how to resolve a criminal investigation, prosecutors focus on two points in time when evaluating a company's compliance program: the time of the alleged misconduct and the time of resolution.

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