At the Annual Compliance conference recently held in London, the session on ‘Supply chains – Navigating ESG and Trade-related Risks’ examined the intensifying ESG and trade-related risks facing global supply chains, shaped by shifting political priorities and evolving regulatory frameworks.
At the Annual Compliance conference recently held in London, the session on ‘US and UK Enforcement in the Current Climate: Strategic Shifts and Global Implications’ explored the evolving enforcement landscape across the UK, US, and Latin America, with a particular focus on strategic priorities, inter-agency cooperation, and the practical implications of recent policy shifts.
In February 2025, the European Commission presented its “Omnibus” package aiming to delay application as well as simplify certain obligations under the CSRD, CSDDD and the EU Taxonomy with the ultimate goal of reducing administrative burden and thus addressing concerns that the rules would hamper European competitiveness (see our summary of the Omnibus here). Following the approval of the “stop the clock” Directive, which delays application of the CSRD and CSDDD for certain companies, the EU institutions are now focusing efforts on the substantive proposal to simplify and streamline certain obligations under these rules. In parallel, the EU Commission is also working to publish updates to the EU Taxonomy.
The Securities and Exchange Commission (SEC) recently published a concept release seeking public comment on redefining the term “foreign private issuer” (FPI). The current framework provides FPIs with less regulation than domestic issuers, based on the understanding that FPIs face different circumstances, such as compliance with home country laws. However, a recent study revealed significant changes in the FPI population, including an increase in China-based issuers incorporated in lightly regulated tax havens. The SEC is concerned that the current FPI definition may no longer be suitable and is considering potential amendments.
Fraud poses significant legal, financial, and reputational risks for organizations. The FBI’s 2025 Internet Crime Report highlights over $16 billion in losses due to internet-related crimes, including phishing, extortion, and personal data breaches. ISO 37003, published in May 2025, provides guidelines for managing fraud risks through prevention, detection, response, and evaluation. Effective fraud control systems help organizations comply with legal standards and mitigate liability. ISO 37003 can integrate with other ISO standards to create a comprehensive Governance, Risk, and Compliance framework, aiding organizations in safeguarding against both internal and external fraud.
The European Commission has issued its first fine in a no-poach case in the labor market, and its first sanction of the anti-competitive use of a minority share in a competing business. With the fine of EUR 329 million, the Commission joins the ranks of a number of high-profile antitrust enforcers worldwide that have targeted HR-related infringements. The Commission’s first intervention is also likely to encourage other EU regulators to follow suit and is an important reminder of the need to carefully manage antitrust risk (specifically information flows) where a company holds a minority shareholding in a competitor.
In response to heightened scrutiny over country of origin declarations amid ongoing global tariff tensions, Singapore Customs issued Circular No. 06/2025 on 9 June 2025 to provide important clarification on the applicable preferential and non-preferential rules of origin when declaring the “country of origin” for importation into, exportation out of, and transshipments through Singapore.
On 12 June 2025, the representatives of the EU Member States in the Committee of Permanent Representatives (Coreper) approved the Council’s negotiating mandate to revise Regulation (EU) 2019/452 (EU FDI Screening Regulation) on the screening of foreign direct investment (FDI). This clears the way for the so-called trialogue negotiations with the European Parliament and the European Commission. The aim of the reform is to strengthen the EU’s ability to respond to security-related risks of foreign investments and forms part of the EU Commission’s agenda of an ‘open strategic autonomy’ – while at the same time maintaining an open and investment-friendly environment.
The new DOJ FCPA enforcement policy emphasizes US national security and business interests, moving away from solely prosecuting bribery of foreign officials. The focus will be on bribes involving Transnational Criminal Organizations (TCOs), cartels, and those impacting US competitiveness or national security. Routine, locally accepted business practices are deprioritized. The DOJ will exercise discretion to determine if conduct genuinely impacts US interests, leaving other cases to the SEC or foreign regulators. This creates a more nuanced and unpredictable enforcement environment, with clarity expected only as enforcement patterns emerge.
In this session, a panel of speakers from across Baker McKenzie discussed global enforcement priorities and challenges. Trends in the EU (such as the proposed EU Directive on anti-corruption) were noted, but the panel focused, in particular, on Asia, Africa and Latin America.