Translation: Anti-corruption compliance program need to find and respond not only to known risks, but also unforeseen and emerging risks. That means a program needs built-in flexibility to meet the challenges of new markets and unexpected exposure, including varying regulatory requirements from one jurisdiction to the next.
In other words, compliance can’t be bottled up and static. That’s a check-the-box approach. Instead it has to be . . . . scalable.
‘Enforcement 40’ for 2020
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