Five Compliance Issues to Watch in 2025

Welcome to the new year, fellow compliance enthusiasts! As you struggle to answer all those emails and calendar alerts you’ve ignored for the last two weeks, allow me to distract you with some of the bigger issues — like, say, the issues that made it onto the annual Radical Compliance list of compliance events worth watching in the next 12 months. 

Every January I try to identify those events likely to happen in the coming year that will be most consequential for corporate compliance and audit professionals. It’s never easy, since there’s always so much going on, and 2025 is especially challenging given the looming arrival of the Trump Administration. Nevertheless, here’s what is on my radar screen… 

Will the corruption prosecution of Gautam Adani continue?

In November U.S. regulators filed corruption charges against Gautam Adani, head of the Adani Group and one of the richest men in India; and a half-dozen of his business associates. All were accused of funneling more than $250 million in bribes to government officials in India, in exchange for lucrative contracts to provide solar power across the country. 

My question is whether the Trump Administration will allow the Adani case to proceed, or if not, will the Administration explain why it’s reversing course. Adani is a rich and well-connected man. If anyone could buy his way out of a corruption prosecution — either by asking Indian prime minister Narendra Modi to exert influence with Trump, or just by donating money to Trump directly — Adani could. 

What signal would that send to the compliance community? Why would anyone take Justice Department rhetoric about a culture of compliance seriously after that, if Trump shows that he’ll intercede to advance some other political or financial interest of his? 

Maybe there are valid reasons to drop the Adani case, but prosecutors would need to provide a full and clear explanation. Otherwise the Trump Administration is inviting all sorts of cynical interpretations, and sending a chill through the ethics and compliance world.

Will anyone be charged personally in the TD Bank compliance scandal?

Banking regulators dropped a huge enforcement action against TD Bank last October for widespread anti-money laundering failures: $3.1 billion in monetary penalties, a laundry list of compliance improvements to make, a cap on the bank’s growth until those problems are fixed, and more. All of this, because TD’s senior executives embraced a “flat cost paradigm” strategy where the bank essentially froze its spending on compliance capabilities even as business boomed and AML risks rose.

So is anyone going to be charged personally for this mess? 

I’m not the only one asking that question. Sen. Elizabeth Warren, who will be ranking Democrat on the Senate Banking Committee, fired off a letter to the Justice Department in October demanding to know why nobody was charged. It’s a fair point, given that senior Justice Department officials squawk all the time about the need to hold individuals accountable for corporate misconduct. 

The criminal indictment against TD certainly reads like individuals could be charged in the future, perhaps even including senior compliance officers at the bank who went along with management’s hare-brained strategy. So will the Trump Administration’s new leaders for the Justice Department pursue that objective of individual accountability, or ignore it? 

What will Paul Atkins say about priorities at the Securities and Exchange Commission?

Trump has tapped Paul Atkins to be chairman of the Securities and Exchange Commission, and barring some dramatic turn of events, Atkins is going to get confirmed. He’ll come to the agency with deeply conservative views on SEC rulemaking and enforcement — so how will Atkins articulate those views to the compliance officers, auditors, and securities lawyers who deal with SEC issues?

I don’t necessarily expect Atkins to deliver a formal speech, although that would be ideal. He could also remake the SEC enforcement manual to constrain the volume or pace of investigations; or push the commission to adopt new statements on monetary penalties (which, I’m sure will be much diminished under an Atkins SEC). He could do lots of things that give us clues, but he’d do everyone a favor by delivering a clear vision of how the SEC will enforce corporate misconduct under his tenure. 

Plus, as I mentioned previously, Atkins last served at the SEC nearly 20 years ago as a relatively powerless commissioner. The corporate governance world has changed dramatically since then. How will his 2000-era views fit into a 2020s world? 

What will happen to the Consumer Financial Protection Bureau?

If any regulatory agency walks around with a target on its back when Republicans are in charge, it’s the Consumer Financial Protection Bureau. So now that Republicans are in charge again, I’ll be curious to see whether they really do try to reform or outright abolish the CFPB.

Granted, Republicans say they want to reform or abolish all government agencies — but the CFPB is an especially interesting case. First, it was established by the Dodd-Frank Act, so abolishing it or changing its structure would require another act of Congress; I wonder whether Republicans have the political will and legislative expertise to pull off a reform so sweeping. 

Second, if Republicans don’t abolish the CFPB, and instead the Trump Administration simply appoints a figurehead director who dithers over enforcement, the Dodd-Frank Act and CFPB rules both allow state attorneys general and banking regulators to bring their own enforcement actions for federal consumer protection law. That’s another reason why the CFPB is worth watching in 2025: even if Washington undermines the agency’s enforcement power, that power will devolve to state-level enforcement. 

So your total compliance risk wouldn’t decline, as much as it would just shift around. Compliance officers need to see whether that scenario comes to pass in the coming year.

Will the DOGE committee actually do anything?

The DOGE committee could herald significant changes for corporate compliance functions. Its promises of sweeping deregulation could transform lots of what compliance and audit professionals do and worry about on a daily basis, and that’s not necessarily a bad thing. 

I’m just skeptical that DOGE is serious about that mission. 

Recall the Wall Street Journal article Elon Musk published in November, where he outlined how DOGE would work. He said a “lean team of small-government crusaders” would identify regulations to be repealed; then the Trump Administration would stop enforcing those rules; and then the Administration would stop spending money budgeted for those rules. Recent Supreme Court rulings would also mean future administrations wouldn’t be able to re-activate those rules without new legislation from Congress.

So does Musk truly want to make the government more streamlined and efficient? Or does he only want to disable the executive branch’s ability to respond to risks and to enforce rules and standards, especially when doing so might cost him money? Somehow I think it’s the latter, and DOGE will collapse under the weight of its own incompetence and incoherence. Which will leave compliance officers still as busy and pressured as ever.

Anyway, those are five events I’ll be watching for this year to see how they might shape the corporate compliance world. Drop me a line at mkelly@radicalcompliance.com and let me know what I’ve forgotten or what’s on your list!