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    Nov. 5, 2025

Risk Assessment for Trump 2.0: Who and When

As enforcement patterns shift during rapid developments in the opening months of the second presidential administration under Donald Trump (Trump 2.0), compliance risk assessments may need adjustment to ensure they remain relevant, defensible and actionable. This third article in a four-part series examines when and by whom compliance risk should be assessed under Trump 2.0. The first article focused on how the basics of risk assessments have changed since January 2025; part two explored the risk areas that may require particular attention and reassessment; and the final article will address how advancing practices in design and the use of data and technology are improving compliance risk assessments. See “GCs’ Increasingly Critical Role in Managing Risk and Ensuring Compliance” (Jul. 2, 2025).

Emerging Global Compliance Standards: AFA, SFO and Eight Common Compliance Elements

The current enforcement environment is “fluid,” Nicola Bonucci, former legal director of the OECD, observed during a panel at SCCE’s 24th Annual Compliance & Ethics Institute. Therefore, “this is the time for companies to decide what and why they are doing compliance, and it cannot be only because they are responding to regulatory questions,” he said. To help companies build their programs, Bonucci and his co-panelists highlighted the strengths and weaknesses of five different sources of compliance guidance. This second article in a two-part series distilling and expanding on the panel’s insights focuses on compliance guidance provided by Agence Française Anticorruption and enforcers in the U.K. It also details the eight common elements of a compliance program. The first article reviewed DOJ guidance as well as resources provided by the OECD and World Bank Group. See our two-part series on the SFO’s co-operation guidance: “A Hard Sell for Self-Reporting” (May 21, 2025), and “Investigation Expectations” (Jun. 4, 2025).

Navigating Corruption Risks in Turkey

Turkey is an attractive market for foreign investors with a population of 85 million people, a geostrategic location straddling Europe and Asia, and a GDP exceeding $1 trillion. But Turkey’s anti-corruption track record raises concerns among international observers. For example, in Transparency International’s 2024 Corruption Perceptions Index, Turkey stood at its lowest score of 34, having been in decline since its peak of 50 in 2013. The Anti-Corruption Report spoke with Serdar Paksoy, founding and senior partner at independent Turkish law firm Paksoy, about the country’s anti-corruption laws, enforcement and related risks for foreign companies. See “How Companies Can Protect Themselves From Secondary Sanctions Liability” (Dec. 4, 2024).

State AG Representatives Disclose AI Regulatory and Enforcement Outlook

As artificial intelligence (AI)-specific legislation is introduced, regulators are making clear that existing consumer protection and privacy laws still apply to issues involving AI. Moreover, just because a state does not have an AI law that addresses a certain activity does not mean that it will not take an interest in what another state is doing. This article synthesizes commentary from the Assistant AG and Chief of the Privacy and Responsible Technology Division in the Massachusetts AG’s Office, and the former Director of Privacy and Tech Enforcement in the Texas AG’s Office, on the current AI legislative, regulatory and enforcement landscape, including private litigation, trends and navigating the investigative process. The discussion, moderated by Orrick, took place during IAPP’s AI Governance Global North America conference. See “Texas Adds New Type of State AI Law to U.S. Regulatory Mix” (Aug. 27, 2025).

Using Technology to Manage Conflicts of Interest

Detecting conflicts of interest (COI) is often an overlooked component of compliance programs, yet it can be a powerful way to anticipate and mitigate business and legal risks. Understanding where employees may have conflicts can head off issues at the pass, and providing a system where employees can disclose their conflicts painlessly and be met with understanding builds confidence in the compliance program writ large. A panel at the SCCE’s 24th Annual Compliance & Ethics Institute discussed how designing a thoughtful COI program using technology and artificial intelligence can strengthen compliance. This article summarizes their tips. See “Managing Conflicts of Interest With Consistency and a Can-Do Attitude” (Feb. 12, 2025).

In-House Expert Joins Steptoe As Partner in D.C.

Steptoe has welcomed Carl Hahn as a partner in the firm’s investigations, white-collar and compliance practice in Washington, D.C. From 2015 to January 2025, Hahn served as vice president and chief ethics and compliance officer at Northrop Grumman, where he led global compliance operations, embedded analytics into enterprise systems and helped establish an AI governance program. For commentary from Hahn, see “In‑House Perspectives on Compliance’s Role in Managing New and Emerging Risks” (May 22, 2024).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.