The edits to the DOJ’s Evaluation of Corporate Compliance Programs (ECCP) that were announced in September 2024 (2024 Edits) were broad, touching on many aspects of compliance programs. The first article of this three-part series about the 2024 Edits discussed the changes related to AI, and the second examined the many edits related to data analytics. This last installment covers changes regarding bread-and-butter elements of a compliance program that are less sexy to discuss but equally important. See “What to Know (and Do) About DOJ’s Efforts to Identify and Prosecute Cybersecurity Fraud Under the False Claims Act” (Oct. 30, 2024).