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Over the last several years, the forces shaping corporate decision-making have shifted dramatically. Geopolitical uncertainty, once considered a distant or episodic risk, has become a constant feature of the business environment.
The recent US Supreme Court ruling in Learning Resources, Inc. v. Trump — and the immediate global aftermath — show just how inextricably tied business operations and geopolitics have become. Trade tensions, regulatory fragmentation, armed conflict, election cycles, and rapidly evolving national policies now influence everything from supply chains to investment strategy. As these pressures intensify, legal leadership has moved closer to the center of enterprise decision-making.
I was really struck by this comment from Donny Ching, former legal director for Shell plc and ACC Global Board member, during our recent InConversation: “I think we’ve now reached peak VUCA, which is just such a challenging world to navigate,” Ching shared. “How do businesses navigate and weather all of these sorts of events and tensions and dilemmas?” I worry that peak VUCA — volatile, uncertain, complex, and ambiguous times — may just be the beginning.
The 2026 ACC Chief Legal Officer Survey, conducted with FTI Consulting, reflects this reality clearly: Across industries and regions, legal leaders are spending more time helping organizations interpret and respond to geopolitical risk, not as a theoretical exercise, but as an operational necessity.
Trade and tariff issues now rank among the top emerging priorities for CLOs, while concern around AI regulation has grown faster than any other risk category year over year. These are not isolated developments; they reflect a world where regulatory and political decisions increasingly cross borders and reshape markets overnight.
For many organizations, geopolitical risk shows up in practical, immediate ways. Shifting trade policies affect pricing and sourcing decisions. Conflicts and sanctions complicate cross-border transactions and compliance obligations. Divergent regulatory approaches to technology and data privacy force companies to navigate inconsistent rules across jurisdictions.
Even changes in enforcement philosophy, particularly as governments recalibrate their regulatory agendas, create uncertainty that legal teams must help manage in real time. I encountered this dynamic firsthand during my tenure as General Counsel of GE Appliances, a Haier company. In both 2021 and 2025, transitions in White House leadership ushered in administrations with markedly different economic and regulatory priorities. During these periods of uncertainty, it was incumbent upon me, as a leader, to ensure that my team continued to provide timely, effective, and strategic support to the business.
In this environment, legal judgment is no longer confined to interpreting statutes or managing disputes after the fact. Increasingly, it involves helping leadership teams anticipate where pressure may arise next.
According to the survey, 74 percent of CLOs report providing proactive strategic counsel, reflecting the growing expectation that legal leaders contribute to forward-looking risk assessment and decision-making. At the same time, 84 percent of CLOs now report directly to the CEO, reinforcing how closely legal insight is tied to enterprise strategy when uncertainty is high.
Technology adds another layer to this complexity. Artificial intelligence is advancing faster than regulatory frameworks can keep pace, and governments around the world are taking markedly different approaches to oversight.
Nearly half of CLOs say their CEOs expect them to develop AI and technology proficiency, not simply to manage compliance, but to help guide responsible adoption amid unclear and evolving rules. This intersection of technology, regulation, and geopolitics has become one of the defining challenges of modern legal leadership.
Yet these expanding expectations come with real constraints. More than a third of CLOs cite limited budgets and resources as their biggest obstacle, even as they are asked to manage more risk across more jurisdictions. As a result, legal leaders are relying on efficiency, collaboration, and strategic prioritization to meet growing demands without commensurate increases in capacity.
Reflecting on my own career, I’ve seen how moments of uncertainty often clarify what leadership truly requires. During the COVID-19 pandemic, leaders were faced with unprecedented circumstances as we needed to guide our organizations through the unknown. As the entire world was attempting to cope with the impact of the “new normal”, leaders had to step up, learn and pivot into unchartered waters to ensure the business would continue, let alone thrive. For me, I even worked on the production line to build some refrigerators during that time.
The current geopolitical climate demands legal leaders who can connect external developments to internal decision-making, who understand not only the law, but the broader context in which the law operates. The 2026 CLO Survey confirms that this capability is no longer optional.
As geopolitical risk continues to shape the global business landscape, legal leaders are increasingly viewed as essential partners in navigating complexity. Their role is not simply to react to change, but to help organizations move forward with confidence in a world where the rules are constantly being rewritten.
Disclaimer: The information in any resource in this website should not be construed as legal advice or as a legal opinion on specific facts, and should not be considered representing the views of its authors, its authors’ employers, its sponsors, and/or ACC. These resources are not intended as a definitive statement on the subject addressed. Rather, they are intended to serve as a tool providing practical guidance and references for the busy in-house practitioner and other readers.
