My thoughts on the recent shake ups...
Yet again, Trump has been true to his seemingly erratic behavior, making sudden decisions that will have major implications for the compliance world. His recent moves include:
Pausing enforcement of the Foreign Corrupt Practices Act (FCPA) – 10 February 2025
Introducing the "Gold Card" Visa Program – 25 February 2025
Suspending enforcement of Beneficial Ownership Information (BOI) reporting for U.S. nationals and companies – 2 March 2025
Trump, in all aspects, plays the disruptor card—for better or worse—whether in defense, Diversity & Inclusion, or now, compliance. Looking at his geopolitical and economic decisions, he forces other countries to take a stance. The same pattern is now at play in compliance.
While it is never truly clear how much foreign companies and individuals will be impacted by his decisions, one thing is certain: institutions and compliance professionals must now rethink their entire approach.
A Shake-Up the Industry Needed?
To be frank, this might not be entirely bad. Let’s be clear—this is not an endorsement of Trump, nor is this article politically motivated. But as someone who has been in the compliance industry for over a decade, I have to admit: this is rocking the boat in ways that force us to reassess.
Over the past few years, the explosion of regulations has led to an equally insane rise in compliance personnel. But has this really reduced risk, or just created more bureaucratic complexity? Too often, compliance follows the “because it’s the law” approach rather than asking whether the rules actually mitigate risks.
Has Compliance Become an Industry of Its Own?
For too long, compliance has been reactive—driven by laws rather than logic. The question is:
Are institutions truly reducing financial crime?
Or are they just engaged in an endless cycle of regulatory catch-up?
Strict regulations offer a comfort zone for many compliance professionals. We’ve been conditioned to see laws like the FCPA as untouchable pillars of financial integrity, with American regulations setting the global tone. Yet, let’s not ignore the contradictions—like how facilitation payments are somehow different from bribery, or how Delaware hosts more shell companies than actual residents.
Compliance Needs More Business Acumen
One of the biggest flaws in the compliance world? A lack of business acumen. Compliance is often seen as a roadblock rather than a business partner. No wonder compliance teams struggle to gain real influence.
I have long advocated for a compliance function that understands business needs, uses common sense, and focuses on real risk management. Regulatory compliance should be about mitigating actual threats—not just fulfilling legal obligations.
What Now? Time to Own Compliance
For compliance officers, these disruptions pose a dilemma: Should compliance be dictated by shifting political trends—or by long-term best practices? Institutions now face a choice:
✔ Reassessing internal risk frameworks beyond regulatory mandates.✔ Developing real governance principles—instead of just layering more compliance policies.✔ Moving away from a box-ticking mindset—toward proactive, risk-based compliance that genuinely protects businesses from harm.
The question is: which path will we take?
