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Abstract: 

Traditional compliance structures are facing new challenges from remote and hybrid workforce environments. In this article, the authors begin by describing in detail these challenges and federal regulators’ heightened expectations for corporate compliance programs. They then turn to two recent enforcement actions to illustrate that DOJ and SEC continue to emphasize high-risk areas and anticorruption controls breakdowns in their evaluations of violations by companies. They close with six steps a company can take to reduce the risks of enforcement actions and FCPA violations.

Keywords: Compliance and Remote and Hybrid Work; DOJ Guidance on Evaluation of Corporate Compliance Programs; Stericycle; Glencore; Digital-Era Compliance Tools

Affiliations:  1: Gibson Dunn & Crutcher LLP; 2: Meta Platforms, Inc..