�鶹ֱ��

For multinational companies, today’s compliance challenge is not merely the number of applicable regulations but the pace of regulatory change, geographic fragmentation, and rising expectations from regulators, investors, financial institutions, and business partners. Enforcement authorities are increasingly aligned in looking beyond the existence of written policies to examine how companies identify and prioritize risk, allocate resources, train personnel, oversee third parties, and respond when issues arise. As a result, an effective compliance program must be dynamic, defensible, and embedded in day-to-day business operations — rather than a static set of documents maintained in isolation.

To help companies navigate this environment, this checklist is offered as a practical self-assessment tool for evaluating corporate governance and overall compliance infrastructure. It is designed to help organizations assess whether they have a functioning, risk-based compliance program, regardless of industry, business model, or jurisdiction. Rather than cataloging obligations under specific laws or regulatory regimes, the checklist focuses on the core building blocks of effective compliance — governance, risk assessment, training, oversight, escalation, and continuous improvement. In short, it asks not simply, “Do we have policies?” but “Does our compliance program work in practice?”

The checklist is intended for internal use by legal, compliance, audit, and business leadership to identify strengths, surface blind spots, and prioritize remediation efforts. A “no” response does not, by itself, indicate noncompliance or a legal violation. Instead, it should be viewed as a potential program gap — an area that may warrant further analysis, enhancement, or documentation based on the company’s specific risk profile.

I.          Tone-at-the-Top, Ownership, and Governance

• Do senior management and the board of directors demonstrate a strong commitment to compliance by promoting ethical conduct, supporting compliance personnel, and ensuring adherence to applicable laws, regulations, and policies?
• Is there clear executive-level ownership of compliance (e.g., a designated compliance leader with defined authority and responsibility)?
• Does the compliance function have direct access to the Board or an appropriate Board committee, with regular, substantive reporting?
• Does the compliance leader have sufficient independence from commercial pressures to escalate issues and raise concerns without interference?
• Does the compliance function have the authority to pause or halt activities when material compliance risks are identified?
• Are compliance responsibilities formally assigned across business units, regions, and functions, including clearly defined lines of accountability?
• Is the compliance function adequately resourced (i.e., personnel, budget, tools) in light of the company’s size, geographic footprint, and risk profile?
• Are compliance expectations reflected in job descriptions, performance evaluations, and management incentives, rather than treated as an informal obligation?
• Are compliance failures addressed through consistent disciplinary processes, regardless of seniority or revenue impact?
• Is compliance viewed internally as a business enabler and risk manager, not solely as a legal or audit backstop?
• Does the organization maintain written governance documents describing compliance roles, escalation paths, reporting lines, and decision-making authority?
• Do Board or committee discussions address not only metrics but also emerging risks, significant incidents, and program effectiveness?
• Is compliance meaningfully integrated with legal, audit, finance, HR, and enterprise risk functions, with defined coordination mechanisms?
• Are compliance considerations embedded in strategic business decisions, such as market entry, restructuring, acquisitions, or changes in business model?

II.         Risk Assessment and Program Design

• Has the company conducted a documented, enterprise-wide compliance risk assessment?
• Is there a defined and repeatable methodology for how compliance risks are identified, evaluated, and prioritized?
• Does the risk assessment involve meaningful input from relevant business units, regions, and functions, rather than being limited to legal or compliance?
• Is the risk assessment updated periodically, and refreshed after major events such as acquisitions, new market entry, changes in business model, or significant regulatory developments?
• Does the risk assessment consider key structural risk drivers, including: (1) geographic footprint; (2) business model and sales channels; (3) reliance on third parties; (4) government touchpoints; and (5) supply-chain complexity?
• Are risks prioritized using consistent criteria (e.g., likelihood and potential impact), rather than treated as equal?
• Are compliance resources, controls, and monitoring activities aligned to the prioritized risks identified in the assessment?
• Can the company clearly explain and defend its risk prioritization and program design choices to senior management, the Board, auditors, or regulators?

III.        Policies, Procedures, and Practical Guidance

• Are core compliance policies written, current, and accessible to relevant employees?
• Are policies supported by practical procedures, playbooks, examples, or FAQs that explain how compliance works in real scenarios?
• Are policies: (1) tailored to the company’s business (not generic templates); (2) reviewed on a regular cadence; and (3) regularly updated to reflect regulatory and operational changes?
• Is there a documented process for policy exceptions, approvals, and interpretations?

IV.        Training and Awareness

• Does the company provide regular compliance training, not just onboarding training?
• Is training risk-based, with enhanced focus for higher-risk roles, regions, or functions?
• Is training: (1) tracked and documented; (2) updated periodically; and (3) delivered in formats employees can realistically absorb?
• Are employees periodically reminded of: (1) where to get compliance guidance; (2) how to raise concerns; and (3) that retaliation is prohibited?

V.         Reporting, Escalation, and Response

• Are there clear, confidential channels for employees and third parties to raise concerns?
• Do employees understand when and how to escalate issues?
• Is there a documented investigation and response protocol for compliance concerns?
• Are issues tracked to resolution, with corrective actions identified and implemented?
• Does the company analyze issues for root causes and systemic weaknesses, not just individual errors?

VI.        Monitoring, Testing, and Continuous Improvement

• Does the company conduct periodic testing or monitoring of compliance controls?
• Are audits or reviews used to assess whether controls actually work in practice?
• Are compliance failures, near-misses, or enforcement actions used as inputs for program improvement?

VII.       Third-Party and Business Partner Oversight

• Does the company maintain a risk-based process for identifying, onboarding, and managing third parties and business partners?
• Has the company clearly defined the scope of third parties subject to oversight (e.g., agents, distributors, suppliers, contractors, consultants, intermediaries)?
• Are third parties risk-ranked using consistent criteria, with due diligence scaled to the level of risk?
• Are third parties subject to: (1) due diligence proportional to risk; (2) contractual compliance commitments; and (3) ongoing monitoring or periodic refresh where appropriate?
• Are red flags, adverse findings, or changes in risk escalated through a defined review and approval process?
• Is responsibility for third-party oversight clearly assigned, including ownership for onboarding, monitoring, and issue resolution?
• Are relevant third parties provided with appropriate compliance training, guidance, or certifications, where risk warrants?
• Are compliance failures by third parties addressed through documented remediation steps or enforcement actions, including suspension or termination when necessary?

VIII.      M&A, Growth, and Change Management

• Are compliance risks identified and assessed early when entering new markets, launching new products or services, or changing business models?
• Is there a defined process to involve legal and compliance in strategic initiatives at the planning stage, rather than after commercial decisions are finalized?
• Is compliance meaningfully integrated into: (1) M&A due diligence; (2) post-acquisition integration planning and execution; (3) joint ventures, strategic partnerships, and minority investments; and (4) major restructuring, outsourcing, or supply-chain redesign decisions?
• Are compliance risks evaluated as part of deal structuring, including allocation of risk, representations and warranties, and post-closing remediation planning?
• Is there a post-transaction roadmap to address identified compliance gaps, including timelines, ownership, and resource allocation?
• Are acquired or newly integrated entities brought into the company’s compliance framework within a defined period, including policies, training, reporting mechanisms, and controls?
• Are changes in geographic footprint, customer base, third-party relationships, or government touchpoints fed back into the enterprise risk assessment?
• Is there a process to track, test, and validate that compliance controls remain effective as the organization grows or changes?
• Are lessons learned from prior integrations, expansions, or restructurings captured and used to improve future change-management processes?

IX.        Documentation and Defensibility

• Can the company demonstrate its compliance efforts with contemporaneous documentation?
• Is there a clear record of: (1) risk assessments; (2) training offerings and completion; (3) policy approvals; and (4) Board or management reporting?

If you would like to help analyzing the results of your compliance self-check, please reach out to the authors or your �鶹ֱ�� relationship attorney.

Would you like more practical compliance tips like these? The �鶹ֱ�� International Trade & National Security Team is monitoring all international trade, enforcement, and compliance developments, which we post as they occur on our Tariff & International Trade Resources blog. for our email list to receive future emails and practical international regulatory compliance tips, including our Tariff-ied! and What Every Multinational Should Know articles.

Our white paper on Managing Import and Tariff Risks During a Trade War outlines a 12-step plan to provide practical steps to help importers navigate the tariff and international trade risks in the current tariff and trade environment, while the companion white paper on Managing Supply Chain Integrity Risks provides practical advice to deal with heightened supply chain risks pertaining to goods imported into the United States, including the increasing use of detentions by Customs.