REASSESSING YOUR COMPLIANCE PROGRAMME POST-COVID-19
With the global economy creeping back to some version of normal as many countries vaccinate significant segments of their populations, many compliance officers are welcoming the return of more predictable budgets. Some companies are clawing back to pre-pandemic bottom lines, while others have recovered more quickly than they planned to, testing compliance departments’ agility. Wherever your company falls on this spectrum, it is a good time to re-evaluate your compliance programme and determine where to allocate current and future resources.
Current enforcement environment
Government agencies show no signs of slowing the pace of anti-bribery enforcement, with 2020 emerging as a record year for the US Foreign Corrupt Practices Act (FCPA), based on the number of fines and penalties issued, and coordination between international authorities at an all-time high. Officials from the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) have repeatedly stated that their pipeline of FCPA cases has “never been stronger”. US authorities have also maintained that the pandemic is not a valid excuse for lapses in anti-bribery compliance and that their expectations remain unchanged. Their intentions are already palpable. The DOJ and other agencies are actively prosecuting companies in financial crime cases related to the pandemic, including fraud and money laundering.
Conducting a transitional risk assessment
To meet the expectations of legal authorities and keep pace with evolving business objectives, compliance officers should consider conducting a transitional risk assessment, even in abbreviated form, to identify inefficiencies and inform decisions about resources and budget.
Jul-Sep 2021 Issue
TRACE