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).
