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Volume XII, Number 267


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International Compliance and Risk Mitigation Heat Map

U.S. companies conducting business abroad face myriad compliance and regulatory challenges. To help mitigate these compliance risks, Foley has created a series of interactive global risk maps that provide quick visual indications of relative bribery, sanctions, and human rights compliance risks in every country around the globe.

Please find below the International Compliance and Risk Mitigation Heat Map.

Bribery/Corruption Risk Heat Map

This map reflects Foley’s assessment of bribery and corruption risk presented by conducting business in various countries around the world. Countries in red are viewed as high risk; countries in orange as medium/high risk; countries in yellow as medium risk; and countries in blue as low risk. Companies should tailor their compliance programs and control procedures based in part on the perceived risk of bribery and corruption presented in their respective countries of operation, taking into consideration the types of business activities occurring in those countries and the degree of interaction with government officials.

U.S. Sanctions Risk Heat Map

This map reflects Foley’s assessment of U.S. economic sanctions risk presented by conducting business in various countries around the world. Countries in maroon are comprehensively sanctioned, and potential transactions involving these countries should not proceed without thorough legal review and authorization given the extremely high risk of violating U.S. sanctions. Countries in red are deemed high risk due to significant list-based sanctions. Countries in orange present moderate risk due to some list-based sanctions, coupled with a relatively high diversion risk. Countries in yellow are subject to limited list-based sanctions but present some risk due to a moderate diversion risk. And countries in blue are not sanctioned and present a low diversion risk. Companies should implement screening procedures of relevant parties that take into consideration the countries associated with the transaction and with the relevant parties.

Forced Labor/Child Labor Risk Heat Map

This map reflects Foley’s assessment of the pervasiveness of child/forced labor used to produce goods in various countries around the world. Countries in maroon are perceived as having the highest incident rates of products made using child/forced labor; countries in red have high incident rates; countries in orange have medium/high incident rates; countries in yellow have medium incident rates, and countries in blue have low incident rates. Companies should tailor their supply-chain due diligence and monitoring procedures to account for the pervasiveness of child/forced labor in the countries from which they source raw materials and other goods.

Christopher Swift and Gregory Husisian also contributed to this report.

© 2022 Foley & Lardner LLPNational Law Review, Volume XII, Number 207

About this Author

David W. Simon, Foley Lardner, Government Matters, FCPA Attorney

David W. Simon is a litigation attorney who devotes much of his practice to helping corporate clients avoid and manage crises that potentially give rise to government enforcement actions. He provides compliance advice, conducts internal investigations, defends companies against enforcement actions, and represents companies in litigation.

The Foreign Corrupt Practices Act (FCPA) is a principal focus of Mr. Simon’s practice. He also has extensive experience representing clients in antitrust matters and in defending False Claims Act investigations...

Rohan Virginkar, Foley Lardner Law Firm, Washington DC, Government Enforcement Attorney

Rohan Virginkar is a former federal prosecutor and a member of the Government Enforcement Defense & Investigations Practice in the Washington D.C. office of Foley & Lardner LLP. His practice focuses on advising corporations and executives on government and regulatory actions; conducting internal investigations; leading corporate compliance matters; and representing individuals and corporations in white collar matters and investigations by the U.S. Department of Justice, United States Attorney’s Offices, the U.S. Securities and Exchange Commission, and other...

Michael J. Walsh Government Litigation Lawyer Foley Lardner Law Firm

Michael J. Walsh, Jr. is a partner and litigation attorney with Foley & Lardner LLP. Based in the firm’s D.C. office, he is a member of the Government Enforcement Defense & Investigations Practice.

Prior to joining Foley, Mike served as Chief of Staff at the U.S. Commerce Department, and he also performed the duties of the General Counsel since August 2019. In this role as Chief Legal Officer, Mike oversaw more than 600 attorneys and was responsible for all legal matters within the Department. He also served as the senior advisor to the Secretary of Commerce on the most...

Olivia Singelmann Government Enforcement Attorney

Olivia Singelmann is an associate and litigation attorney with Foley & Lardner LLP. She is a member of the firm’s Government Enforcement Defense & Investigations, Business Litigation & Dispute Resolution, and Securities Enforcement & Litigation Practices.

Olivia’s practice includes litigation matters, with a focus on representing clients in investigations and/or enforcement proceedings by the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), and the Public Company Accounting Oversight Board (PCAOB). Olivia has experience representing...

John E. Turlais, Foley Lardner, Litigation Lawyer, Internal Investigations
Special Counsel

John Turlais is senior counsel and a litigation lawyer with Foley & Lardner LLP where he focuses on conducting internal investigations and defending corporate clients facing enforcement actions by the Department of Justice, Office of Thrift Supervision, U.S. Postal Inspection Service, Immigration and Customs Enforcement, or other federal or state agencies. Mr. Turlais has conducted numerous internal investigations involving corporate compliance with government regulations and federal laws, as well as investigations relating to internal or external company matters,...