Governance Above And Beyond Compliance

Once it was possible to satisfy regulators by having a compliance officer check a series of boxes. This is no longer the case, as companies are now expected to maintain compliance programs tailored for their industries, their business lines, geographic region, work force and the particular risk factors they are positioned to encounter. A wide range of regulatory actors, including DOJ, the Treasury Department, the state of California through its supply chain legislation, and the EU through a broad range of human rights and other regulations, have signaled this new emphasis. A Today’s General Counsel article explores the trend, how it’s forcing companies to think differently about compliance, and in particular what questions general counsel need to ask about their programs and procedures.