What has been the number one challenge that has impacted you over the past year?

The most significant challenge has been designing and developing compliance departments from scratch, in companies that had no previous knowledge of the subject.

Secondly, while it is relatively easy for a company to prepare for a change originated by a new law because it is mandatory, establishing structural changes in matters that are not necessarily mandated by law is a major challenge.

Simultaneously homologizing cultural differences, educational levels, and legal requirements for more than 11 countries is also challenging on resources and holds a reasonable level of risks in each one of them.

The biggest challenge has been auditing a pre-existing ethics report channel, verifying its failures, deconstructing it, finding opportunities for improvement, and successfully relaunching it. Hence, a simple email was converted into an ethics report system, with a brand-new global Code of Ethics, applicable in Canada, US, Mexico, Central America, Peru, and Argentina, a professionalized committee with global reach and reinforced with a training and institutional communication scheme

This training plan was established annually, is accessible to all levels of the company and can be carried out asynchronously, at various levels and with evaluations that allow us to review all personnel’s knowledge.

I started with a new challenge, having decided to retire from my permanent functions as in-house counsel at PAE GLOBAL, to begin a role as an external consultant in legal matters and regulatory compliance strategies at a global level.

In which ways have you attempted to bring the legal department closer to your business colleagues?

Communication between the compliance department and other areas may be difficult to achieve. Without collaborating with other departments, such as Human Resources, senior management, and others, it would be an impossible task to accomplish.

During the first year we invested time in adapting technical legal language on difficult topics – data privacy, ethics, anti-corruption and bribery, money laundering prevention, among others – to a more understandable language, suitable for all levels of employees.

What are some of the most significant cases and transactions you have been involved in recently?

We have focused on the design and implementation of a money laundering prevention system, mainly in countries where it has not only become a legal requirement, but also a requirement of relevant clients.

Aspects such as KYC of third parties, transaction monitoring and adoption of manuals in unregulated companies, require significant intervention in order to balance legal requirements with business needs.