The COVID-19 pandemic national emergency has changed the way organizations are conducting business. As businesses adapt and begin to adjust to this new environment, it is important not to lose sight of the policies and procedures that guard your business from compliance risk. Below are a few areas to keep top of mind during these tumultuous times in order to protect your business:
- Continued enforcement of policies: Most importantly, even as the working environment changes, compliance with anti-corruption and company policies cannot be put on hold. Compliance professionals must maintain their presence in the organization and clearly communicate that integrity and compliance with company policies is a priority. It will be no excuse later that corrupt payments were made or policies were violated in order to make up for lost revenue during this period.
- Employment Compliance / Stay Home/Work Safe / Shelter-in-Place: The Federal government recently passed the Families First Coronavirus Response Act, which covers paid sick leave, virus testing, and food assistance and unemployment benefits, among other protections. In addition, local governments are issuing shelter-in-place or Stay Home/Work Safe orders. If your business is not in one of the 16 critical infrastructure sectors, it is likely impacted in some way. It is important to be up to date on the latest regulatory changes and have advisors that can help you navigate the changing landscape.
- Be on the watch for fraud: Federal governmental bodies are already issuing warnings of the threats of potential fraud against businesses. In addition, individual employees may be targets of cybersecurity threats or other scams. It will be important to stay in regular communication with employees about being vigilant in combating fraud.
- Policy tweaks for new working environment: This may be an appropriate time to review company policies to see if revisions are needed related to financial controls or business continuity plans in the midst of remote working environments, travel restrictions, or other business changes. Many changes are occurring quickly and some may be lasting. Continual updating of policies to keep them current and in accordance with best practices should be part of the routine compliance process, and the current situation may provide a push to get those updates implemented.
For additional resources on COVID-19, please refer to the Porter Hedges COVID-19 Business Resource Center.
Heather Hatfield represents clients in corporate investigations, white-collar crime investigations and defense involving the Foreign Corrupt Practices Act (FCPA), complex contract disputes, oil and gas litigation ...
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