In a compliance environment shaped by shifting enforcement priorities, companies may need to reassess how they evaluate complaints, triage allegations and decide when an internal investigation is warranted. This article distills insights offered by three former prosecutors, all with significant in-house investigations experience, on how they are rethinking their internal investigations playbook to account for emerging areas of risk. The discussion, which took place during a webinar co-hosted by the Anti-Corruption Report and the American Conference Institute (ACI) as a lead-up to ACI’s 43^rd Annual Conference on FCPA and Global Anti-Corruption to be held in December 2026, offers concrete guidance for compliance teams on escalating concerns and allocating investigative resources. See “Adapting Compliance Programs to Manage Criminal and Civil FTO Risk” (Aug. 12, 2026).