Welcome back to the podcast, bribe, swindle, or steel.

I'm Alexander Rogge, and as we near the end of the year, I've asked compliance experts to share their predictions for 2023.

First up is Jonathan Drimmer.

Jonathan is a partner in the investigations and white-collar defense practice at Paul Hastings,

former Deputy General Counsel and Chief Compliance Officer at Barrett Gold,

and he previously served in the Department of Justice.

Jonathan, over to you to kick off our predictions for 20-23.

It really remains to be seen what 2020-3 is going to bring. And I actually feel less

confident in most of the issues that I track for 2023 than I have in years past this time of

year. But there are two that I do want to bring up that I do think are worth looking for. So number

one, we haven't yet seen the predicted flood of cases that are coming out of the pandemic. There's been a

massive influx of government aid programs over the last several years, and in the past, those have

brought with them very significant investigations and prosecution risks. Now, it is true during the

pandemic. There was less direct interface with public officials, which might reduce the risk overall.

But I still think we are going to see an uptick next year in cases that have some connection directly or indirectly COVID-19.

But the larger issue I do want to talk about that I think is going to be a new one, it's already becoming a new one for corporate compliance programs and it's going to continue to grow throughout 2023 is the integration of human rights and related sustainability areas. We are already seeing substantial efforts that are in part being driven out of Europe. Regulations are now in place around mandatory

human rights due diligence in France and Germany, as well as to some extent in Switzerland,

as well as in Norway. So several of the big EU member states, there are proposals that are being

considered in Spain, in the Netherlands, in many other locations throughout the

continent. They're working on an EU-level draft for mandatory human rights due diligence,

and there's a possibility that governance and corruption will be integrated into it, along with

environmental issues and human rights, which are already part of the draft. We're already seeing

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