Turning Compliance into Culture: How the DOJ’s ECCP Framework Can Strengthen Programs Across Asia-Pacific

Rethinking Compliance in an Era of Global Accountability

Compliance isn’t just a legal checkbox anymore — it’s a defining element of organizational resilience and integrity. Regulators, investors, and employees alike are holding companies to a higher standard, demanding that ethics and compliance programs are more than theoretical frameworks or glossy training videos.

The United States Department of Justice (DOJ) has set a global tone through its Evaluation of Corporate Compliance Programs (ECCP), a guidance document that’s increasingly shaping how compliance is judged — not just in the U.S., but across interconnected markets, including Asia-Pacific.

The ECCP framework has become a widely referenced benchmark for evaluating whether a company’s compliance program is not only well-structured but actually functional. For organizations of all sizes operating in Hong Kong, Singapore, Tokyo, Sydney, or Jakarta, this framework offers a valuable roadmap for designing, implementing, and maintaining an effective compliance culture.

Why the ECCP Is Gaining Relevance Across Asia

Although developed by the DOJ, the ECCP has global implications. Regulatory bodies in Hong Kong, Singapore, and Australia — as well as multinational corporations headquartered in Asia — are increasingly aligning their compliance strategies with ECCP principles.

Recent investigations into companies both large and small show that no organization is immune from scrutiny. And with growing collaboration between regulators across jurisdictions, the need for proactive, demonstrable compliance programs is more important than ever.

Designing a Program That Fits Your Risk Profile

The first focus of the ECCP is whether a company’s program is well-designed. This doesn’t mean simply purchasing a template and applying it across regions. It means tailoring policies, procedures, and controls to reflect the company’s actual risk environment.

For businesses operating in Asia-Pacific, this could include:

• Conducting localised risk assessments based on political, economic, and cultural variables.

• Creating multilingual, culturally appropriate codes of conduct and policies.

• Ensuring training content speaks directly to the roles and realities of employees in markets like Vietnam, South Korea, or the Philippines.

• Establishing clear and accessible reporting channels — web portals, mobile apps, or anonymous helplines — that respect regional sensitivities around whistleblowing.

  
  

A well-designed program reflects the actual operations and exposures of the business. It’s built to protect the organization from real risks — not just regulatory optics.

Bringing Programs to Life with Authentic Implementation

The second principle of the ECCP framework is that a program must be implemented in good faith. In other words, compliance must be embedded in the day-to-day functioning of the organization.

This requires more than policies on paper. It involves:

• Leadership commitment, where senior executives regularly speak to the importance of ethics and back it up with their actions.

• Empowering compliance teams with autonomy, resources, and access to decision-makers.

• Fair and consistent enforcement of rules — without exceptions for top performers or senior leaders.

  
  

Across Asia-Pacific, where business cultures can vary significantly, this means ensuring the tone from the top is matched by consistent behavior across regional offices. Programs that lack authenticity or are seen as performative will fail to build trust and engagement.

Measuring What Works and Learning from What Doesn’t

The third element of the ECCP is its most practical — does the program actually work? The DOJ, like many regulators, isn’t looking for perfection. Instead, it seeks evidence that the compliance function is capable of detecting misconduct, responding appropriately, and adapting over time.

For organizations in Asia-Pacific, this could include:

• Reviewing training completion rates and test results to identify knowledge gaps.

• Conducting anonymous culture surveys to understand employee comfort in raising concerns.

• Auditing internal controls in high-risk operations, such as procurement or third-party onboarding.

• Learning from investigations by ensuring incidents lead to root cause analysis, revised training, or policy updates.

  
  

Effective compliance programs are dynamic. They evolve alongside the business, respond to new threats (like generative AI misuse or cybersecurity breaches), and demonstrate a willingness to improve.

Beyond Legal Defense: Building a Culture of Integrity

When used proactively, the ECCP framework is more than just a guide for avoiding fines. It becomes a strategic tool for shaping corporate culture, building trust with stakeholders, and future-proofing business operations.

A strong compliance program does more than prevent wrongdoing. It creates an environment where employees feel safe speaking up, customers trust the brand, and investors have confidence in the company’s leadership.

In the Asia-Pacific region — where markets are fast-moving, regulatory expectations are rising, and corporate reputations can be built or broken overnight — this kind of foundation is invaluable.

Looking Ahead

Whether your organization is building its first formal compliance program or evolving a mature framework, the ECCP offers clear and practical guidance. By focusing on thoughtful design, genuine implementation, and measurable impact, companies across Asia-Pacific can build programs that aren’t just compliant — they’re credible.

As expectations rise and cross-border enforcement becomes the norm, those who lead with ethics, transparency, and accountability will be the ones that thrive.