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Now that we better understand the shifting regulatory environment, how should companies be responding to change through their compliance programs — beyond investing in technology for process and automation improvements?  This Freshfields blog walks through four regulatory areas of interest — including FCPA compliance, newly designated terrorist organizations, DEI policies and tariffs. The blog then shares some actionable steps compliance professionals should consider to enhance their companies’ compliance programs in light of current federal regulatory priorities.

Here they are:

– Conduct ongoing assessments of legal and compliance risks to business operations in light of these new enforcement priorities, so that corporations may deploy compliance resources appropriately, particularly where there may be differences in applicable laws, policies and enforcement priorities across different jurisdictions relevant to multinational corporations (e.g., with regard to anti-bribery and corruption, DEI, and international trade and sanctions).

– Evaluate existing due diligence processes and KYC protocols, and whether any such processes should be amended to reflect evolving priorities, including for instance:

• enhancing due diligence of vendors, suppliers, and other third party intermediaries in Mexico and other Latin American countries to address potential exposure to sanctioned parties including newly designated terrorist organizations; and
• reviewing global supply chain due diligence and monitoring processes, particularly relating to suppliers located in jurisdictions that have been targeted by recently announced tariffs.

– Enhance compliance policies and trainings for relevant employees in jurisdictions or business functions potentially subject to increased risk, such as by providing specific training for identifying and mitigating potential risks associated with conducting business operations in Latin American countries and along trade routes where recently designated terrorist organizations (cartels and transnational criminal groups) are perceived to be embedded in the local economies.

– Update compliance hotlines and internal communication pathways so that relevant stakeholders may raise any concerns, and legal and compliance teams may promptly and appropriately triage, investigate, and address such matters.

We’ve been posting tons of memos in our “Regulatory Reform” Practice Area on TheCorporateCounsel.net. Also, be sure to check out our “Compliance Programs” Practice Area.

– Meredith Ervine