The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that provides important direction on the design and implementation of an effective compliance program.  DOJ understands the importance of this document. 

In recognition of evolving technology and compliance program innovations, DOJ updated its guidance to incorporate new technologies and risks in response to the development of artificial intelligence (“AI”) capabilities. At the same time, DOJ added important language to address: (1) risk assessments and risk-based allocation of resources; (2) policies and procedures; (3) training; (4) investigations and retaliation; (5) third-party management; (6) compliance access to data; (7) mergers and acquisitions and post-acquisition integration; (8) compliance autonomy and resources; (9) compliance program effectiveness measurement; and (10) compliance program track record in detecting and preventing misconduct.