The COVID-19 pandemic has had an impact on nearly all aspects of businesses and governments around the world, including the conduct of internal investigations and law enforcement actions, but taking steps to remain fully compliant with policy and law has been further complicated by inconsistencies in enforcement from one jurisdiction to the next. In some jurisdictions, we have noted a continued slowdown in law enforcement activity, while in others we are seeing a relative return to normalcy. The challenge at the heart of the pandemic, given this range of official responses, is that while law enforcement may not be as visible, the expectations of governance, compliance, self-reporting, or response to criminal misconduct remain largely unchanged.
Providence and lessons from the 2008 financial crisis have provided some useful insights on how criminal misconduct risks, including increased fraud and bribery, intertwine with pandemic-related business disruption. Against this backdrop, our expert panel – covering the United States, United Kingdom, Germany, and India – will discuss how internal investigations and law enforcement expectations may have changed, how companies should respond to such issues in the new normal, and suggest best practices to mitigate or avoid government investigations.
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