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2022 Compliance Outlook Newsletter


In this newsletter, we review the following three key developments that took place in the area of criminal investigations and criminal procedure in 2021:

A. Shift of Investigation Authority & Criminal Procedure Reforms

The past year began with a dramatic legislative overhaul that came into force, shifting the balance of power between police and prosecutors, and making changes to key aspects of criminal procedure.  In the year since, we have seen a notable increase in police investigations as well as the adoption of various measures to strengthen due process, but the changes have come with delays and lengthy procedures.  As the police and prosecutors settle into their new roles, we expect more criminal enforcement activity in the coming year, especially after the Presidential Election in March 2022.

B. Enactment of the Serious Accidents Punishment Act (SAPA)

This year also began with a dramatic legislative development of a different nature: the SAPA came into force on January 27, 2022, expanding the scope of liability for a company’s senior management in the event of “serious accidents” (resulting in at least one fatality or threshold numbers of injuries)—even those that occur in certain subcontracting and outsourcing arrangements.  The SAPA was passed as the result of increasing calls for corporate accountability in the event of serious accidents, so we can expect aggressive enforcement now that the law is in effect.

C. Whistleblower Reporting Activity

Meanwhile, 2021 marked the ten-year anniversary of the Whistleblower Protection Act, and we have seen continuous increases in both public and internal whistleblowing activity since it was enacted.  We expect this trend to continue, with the widening scope of the Whistleblower Protection Act, large reward payouts, and increased public awareness of whistleblower protections and rewards. 

For more detailed information on the above issues, please refer the the attachment.

Attachment 2022 Compliance Outlook Newsletter.pdf