What Do Regulators Expect? How To Navigate Recent Regulatory Guidance Regarding Effective E&C Programs
Adapting to new risks is a key focus of US and other regulators’ guidance in the past two years. The U.S. Department of Justice’s Fraud and Anti-Trust Divisions, The UK Serious Fraud Office, France’s Anti-Corruption Agency and the U.S. Treasury’s Office of Foreign Assets Control guidance strongly emphasizes that effective ethics and compliance programs are dynamic--not static--and evolve based on changes in business environments. Avoiding “cruise-control” and “blind benchmarking” are hallmarks of the new guidance. The adaptations and innovations undertaken by many E & C programs to meet COVID-related challenges are examples of effective programs in action, consistent with regulators’ expectations.
Learn what works and where to focus to drive principled performance for your ethics and compliance program.