Formal programs are not enough. The Office of the Comptroller General (CGU) has prioritized evidence of effectiveness, integration with actual business risk, and concrete capacity for prevention, detection, and response. This session proposes an applied approach, based on successes and failures, to discuss how decisions are made, how programs are structured, how sanctions are applied, and which factors influence outcomes, with a focus on effectiveness, proportionality, and defensibility. It also explores how organizations have reacted to investigations, conducted processes, and made decisions regarding cooperation and leniency, focusing on what works, what doesn’t, and how to strengthen prevention and response capacity.

Although many risks are already known, due diligence processes still rely on traditional verification approaches that are not fully adapted to today’s complexity. Fragmented global supply chains, opaque third parties, new business models, and emerging risks demand new perspectives and sources of analysis. This panel proposes a practical reflection on how to go beyond checklists, exploring new verification approaches, lessons learned from recurring mistakes, and the smarter use of technology to support proportional, clear, and defensible decisions.