The IBM settlement was not about new legislation. It was about programs built in good faith under prior guidance, reinterpreted under a new enforcement lens. For GCs, the question is no longer whether your programs are well-intentioned; it is whether they survive scrutiny under a standard that did not exist when you designed them.

• Understand the gap between legal change and enforcement change, and what it means practically for which programs to modify, preserve, and document.
• Navigate the live tension between federal enforcement priorities and state or municipal law pointing the opposite direction, without abandoning your company's values or creating liability on either front.
• Leave with a compliance posture built to survive the current environment and the next one.