Against the backdrop of major military conflict in Europe and a post-COVID world, dealing with novel areas of risk has become a common theme for compliance, risk and legal professionals.
Anti-Corruption and International Risk Global Co-Chair, Amanda Raad, moderated a panel at the Economic Crime Prevention and Compliance Conference this week on the topic of how compliance programs can effectively capture novel risks.
It came as little surprise that the majority of the audience identified sanctions as the newest, and most challenging area of risk that organizations have had to grapple with this year.
Significantly, because of the attention sanctions have received in the media and amongst global regulators, pushing sanctions compliance has rapidly featured as top of the agenda for most organizations.
Indeed, as Laura Atherton (General Counsel, Global Health Unit, GSK) pointed out - not too long ago, compliance personnel were taking the lead navigating organizations through a different global crisis, COVID-19.
Panelists certainly agreed that addressing widely publicized global risks have provided them a platform to bring together different units within their organizations to bring about a sea change in compliance.
But what happens when novel risks are not as global or publicized, does it receive sufficient attention within organizations?
It was interesting to find that although sanctions have remained a dynamic compliance minefield, the audience identified two other risk areas they felt were inadequately addressed in their organization's compliance program: (i) third parties; and (ii) sexual misconduct.
Admittedly, third parties have increasingly received new focus with sanctions compliance requiring organizations to conduct adequate diligence and screening. But what about sexual misconduct, a risk area that often only receives attention within an organization when an issue comes to light?
Being plunged into a major military conflict in Europe right after a post-pandemic world, have compliance teams looked to the horizon to consider what novel risks they should anticipate and address?
If sexual misconduct is a compliance risk area that your organization could better address, Ropes & Gray will be co-hosting alongside ACi an expert panel and training event in London focusing on Investigating Sexual Misconduct on Friday 14 October.
- Amanda Raad (ACIR Global Co-Chair, Ropes & Gray)
- Ruby Moshenska (Safeguarding Consultant)
- Sharon Tan (Partner, Mishcon)