September 2024
In the recent speech by Nicole Argentieri, Head of the DOJ’s Criminal Division, new updates to the Evaluation of Corporate Compliance Programs (ECCP) were introduced. Argentieri underscored three essential areas for compliance teams: access to data, the rise of AI risks, and the importance of proportional resource allocation.
Argentieri’s message was clear: compliance programs need to evolve alongside business operations, with a strong emphasis on utilizing data effectively, managing technology risks, and addressing the imbalance in the level of support and resources the business growth initiatives and compliance departments receive.
Key Takeaways from the DOJ’s Updated Guidance
Access to Data and Analytics
Data access is at the heart of compliance success. The DOJ asks: “Do compliance and control personnel have sufficient direct or indirect access to relevant sources of data to allow for timely and effective monitoring and/or testing of policies, controls, and transactions?” (ECCP, p. 13). Often, trade compliance professionals struggle with incomplete data, preventing them from having the comprehensive oversight they need. SEIA bridges this gap by integrating all relevant data sources into one, ensuring that compliance teams have the visibility needed for thorough, accurate transaction analysis.
By centralizing critical data, SEIA allows compliance officers to access data instantly, conduct risk assessments, and effectively monitor and test controls. This streamlined access means compliance teams can identify issues in real time, avoiding blind spots that could lead to costly violations.
Proportional Resource Allocation
One of the key updates in the ECCP emphasizes the imbalance many companies face when it comes to allocating resources for compliance. The DOJ asks: “How do the assets, resources, and technology available to compliance and risk management compare to those available elsewhere in the company? Is there an imbalance between the technology and resources used by the company to identify and capture market opportunities and the technology and resources used to detect and mitigate risks?” (ECCP, p. 13). At SEIA, we frequently see that compliance departments are often underfunded compared to revenue-generating areas, despite the critical nature of their work.
SEIA’s platform offers a cost-effective solution that maximizes the use of compliance resources by automating risk detection and providing actionable insights.
Data Quality and Transparency
Transparency and data quality are essential for any successful compliance program. The ECCP guidance asks, “To what extent does the company have access to data and information to identify potential misconduct or deficiencies in its compliance program?” (ECCP, p. 19). Data gaps or low-quality data can leave companies vulnerable to non-compliance risks.
SEIA addresses this by identifying gaps in compliance programs and data quality issues that may be exposing you to risk. For example, we can detect when IT systems are not performing their function as intended or when data is missing or incorrect, ensuring that these issues are addressed before they escalate into regulatory problems. By leveraging SEIA’s analytics, companies can maintain full transparency and oversight of their compliance landscape, preventing risks from slipping through the cracks.
How SEIA Can Help
The DOJ’s updated guidance makes it clear that compliance programs must adapt to meet modern challenges. Data access, proportional resource allocation, and transparency are no longer optional—they are essential for compliance success. SEIA is designed to meet these needs by providing companies with comprehensive data access, cutting-edge analytics, and a powerful platform to identify and manage compliance risks. Our solutions help your compliance team stay aligned with the DOJ’s expectations while minimizing risk exposure and maximizing operational efficiency.
Is your company is ready to strengthen its compliance program in line with the latest regulatory standards? SEIA is here to help.
Contact us today to learn how we can support your compliance journey.
U.S. Department of Justice Criminal Division, Evaluation of Corporate Compliance Programs (Updated September 2024), available here.
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