The COVID-19 emergency has forced companies across the world to make rapid supply chain shifts.  While the speed and scope of these shifts is unprecedented, the compliance risks they pose are not.  Any shift to a new supplier or intermediary carries with it a host of potential dangers, not the least of which is liability under the Foreign Corrupt Practices Act or the False Claims Act. 

My colleagues at Baker & McKenzie offer three useful proactive steps to help insulate companies from liability both in the current crisis and in future emergencies.