Apr. 9, 2025

Rethinking Click-Through Training: Maximize Effectiveness With Customization

Off-the-shelf click-through training is attractive for many companies because it is cost effective and easy to deploy. However, while customized content can be pricier, it can also lead to better learning outcomes and behavior changes. This second article in a three-part series discusses making click-through training more effective through design and customization and then measuring the results. The first article focused on the development of click-through training and some of its benefits and drawbacks. The final article will address integrating click-through training into a broader training program and explore how to choose the right vendor. See “How Ericsson Made Compliance Training Must-See TV” (Mar. 12, 2025).

Reference Guide to 2025 Executive Orders for Compliance Professionals

Since President Donald Trump took office on January 20, 2025, there has been a veritable avalanche of executive orders (EOs) and memoranda touching on almost every aspect of the federal government and much of American life. Though it can be challenging to track all the changes, compliance professionals must keep abreast of the EOs and other updates that directly impact their work. To make staying on top of the developments as painless as possible, this quick guide compiles the EOs most relevant to compliance professionals, arranged in date order with links to germane documents, and distills the critical details of each. See “A Quick Look at 2024 Anti-Corruption Enforcement Developments” (Jan. 15, 2025).

TI Sees Hope in Digitalization Despite Global Corruption Rise

Every year, Transparency International (TI), the German-based research association, updates its Corruption Perceptions Index (CPI), which measures internal perceptions of corruption in individual countries. The CPI ranks 180 countries and territories according to the levels of public-sector corruption perceived by experts and businesspeople, relying on 13 independent data sources. Summarizing its 2024 CPI results, TI has released a report (Report), which discloses that perceptions of corruption are increasing in many countries across the globe. The Anti-Corruption Report spoke with experts in the field about the Report and what it means for companies. See “Whistleblowing Directive and U.A.E. Efforts Emerge As Key Anti-Corruption Trends” (Feb. 14, 2024).

CFTC Advisory on Self-Reporting, Cooperation and Remediation Overhauls Years of Guidance

To achieve “regulatory consistency, transparency and clarity,” the Commodity Futures Trading Commission (CFTC) Division of Enforcement (Division) has issued an advisory (Advisory) with guidance to its staff on evaluating matters that they recommend to the Commission for enforcement. This article parses the Advisory’s instructions on evaluating self-reporting, cooperation and remediation, as well as the associated statements of CFTC leaders. See our two-part series on revisions to the DOJ’s Corporate Enforcement Policy: “A More Amenable DOJ Looks to Negotiate” (Feb. 1, 2023), and “Parsing the Policy for the Path to a Declination” (Feb. 15, 2023).

Implications of the Trump AI Executive Order

After rescinding former President Joe Biden’s artificial intelligence (AI) executive order (Biden EO) in his first week in office, President Trump issued his own executive order (Trump EO), which calls for a new federal AI Action Plan that focuses on reducing regulation and prioritizing innovation. In this guest article, ZwillGen attorney Jey Kumarasamy explores the potential impacts of the revocation of the Biden EO, including the fate of voluntary guidelines and the de-emphasis of risk management, and delves into what to expect from the AI Action Plan that will be developed under the Trump EO, highlighting the new administration and industry’s latest comments on AI. See our two-part series on the FCPA Executive Order: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

Former CFTC Director of Enforcement Joins Sidley

Sidley has welcomed Ian McGinley as a securities enforcement and regulatory partner in New York. McGinley most recently served as the Director of Enforcement for the U.S. Commodity Futures Trading Commission (CFTC). For commentary from McGinley, see “Binance’s $4.3‑Billion Criminal Resolution Raises Questions on Crypto Guidance” (Jan. 31, 2024).

McDermott Adds Regulatory and International Trade Partner in D.C.

McDermott Will & Emery has welcomed Darshak Dholakia as a partner in its regulatory practice group in Washington, D.C. He joins from Dechert. For insights from McDermott, see “M&A Considerations for the New Frontiers of U.K. Compliance Risk” (Mar. 26, 2025).