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Using Anti-Bribery and Corruption Regimes for ESG Concerns
Compliance leaders recognize that Environmental, Social and Governance (ESG) is a growing concern for U.S. companies, but face challenges in determining how to embed compliance structures into their programs. One solution is to look to already existing anti-bribery and corruption (AB&C) compliance measures. Despite perceptions that these regimes may compete for compliance resources, they can in fact work in tandem to leverage existing resources to establish a more comprehensive compliance program.
The Importance of ESG
It is clear — ESG concerns are top of mind for compliance professionals. In Steering the Course III: Navigating Deep Waters, a recent study conducted by Hogan Lovells of 600 chief compliance officers (CCOs), heads of legal, or equivalent executive roles (referred to collectively as "compliance leaders") from around the world, over 80% of compliance leaders identified ESG risk as a current and future priority in their business strategies. These compliance leaders noted that integration of ESG programs would positively impact their organization's reputation.
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New York's Latest Cybersecurity Commitment
On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
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