The corporate compliance landscape is undergoing a dramatic transformation, and artificial intelligence stands at the center of this change. With the U.S. Department of Justice’s latest update to its Evaluation of Corporate Compliance Programs (ECCP), one thing is clear: Technology is no longer just a tool for compliance — it’s becoming the cornerstone of effective compliance programs.
The DOJ’s message is unmistakable: Companies need to think differently about how they approach compliance in our increasingly digital world. Gone are the days when compliance officers could operate in isolation from their technology teams. The new guidelines put technology front and center, particularly focusing on artificial intelligence and emerging technologies.
What’s really changed?
The updated guidelines break new ground by specifically calling for companies to do the following:
- Assess how they’re using new technologies, including AI, and understand whether and how technology creates legal and compliance risk for the company
- Develop robust processes for identifying and managing technology-related compliance risks
- Implement specific controls to ensure AI systems operate within legal boundaries
- Integrate compliance considerations into technology development from day one
- Explore how to integrate technology and AI into the compliance program
Why this matters now
This isn’t just another regulatory update — it’s a fundamental shift in how companies need to think about compliance. As organizations rapidly adopt AI and other advanced technologies, the line between technology decisions and compliance risks has become increasingly blurred.
A chatbot that inadvertently shares sensitive information or an AI system that makes biased decisions can create serious compliance issues that traditional programs aren’t equipped to handle.
To meet these new expectations, companies need to take several key steps:
1. Bridge the tech-compliance divide
Create direct channels of communication between compliance and technology teams. This isn’t about occasional meetings — it’s about establishing ongoing collaboration where compliance professionals are involved in technology decisions from the start.
2. Conduct a technology audit
Take a comprehensive inventory of how your organization uses technology, particularly AI systems. Understand not just what technology you’re using, but how it intersects with your legal obligations.
3. Develop new expertise
Many compliance teams will need to expand their technological expertise. This might mean hiring professionals with both compliance and technology backgrounds or investing in training for existing staff.
4. Build automated compliance systems
Look for opportunities to use technology to strengthen compliance monitoring and reporting. AI can be particularly effective at identifying patterns and potential violations that human reviewers might miss.
Looking ahead
The DOJ’s new guidelines signal a future where technology and compliance are inseparable. Organizations that embrace this change — building compliance considerations into their technology strategy from the ground up — will be better positioned to navigate an increasingly complex regulatory landscape.
For compliance officers, this is both a challenge and an opportunity. Those who can effectively partner with their technology teams and leverage AI and other emerging technologies will be able to build more robust, effective compliance programs that can keep pace with rapid technological change.
The message is clear: The future of compliance is digital, and the time to adapt is now.
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