The combination of continuing challenges arising from COVID and potential future economic headwinds could create a perfect storm for misconduct. Companies would be wise to reflect on 2022 to prepare for what maybe ahead in 2023. We set out below some questions for compliance teams to consider.

Introspection - Looking back

  • Infrastructure: Where has our compliance infrastructure been affected – morale; attention; communication; resources?
  • Technology: Lockdowns accelerated the use of Zoom, Teams and other platforms. How can we utilize that (and technology more generally) for our benefit?

Remediation - The present

  • Remote Working and Hybrid Work Models: As employees returned to the workplace, what are the permanent changes to how we work? How does that impact our compliance communications, monitoring and investigations?
  • Continuing practical issues: Are there any areas of risk leftover from lockdowns that have not been addressed? For example, have employees become used to using messaging platforms such as WhatsApp and WeChat for communications instead of company-designated channels?
  • Warning signs: Are we seeing increases in, or different types of, “bad habits” as employees have returned to the workplace? Could they indicate more serious concerns?

Looking forward - The future

  • Risks:  What are the key risks we may face?
  • Priorities: What will be our compliance priorities going forward, particularly if resources are reduced due to economic constraints?

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.