Your Employment Lawyer Wrote a Memo. Now What?

Most Illinois employers we talk to already have the memo. A good one, usually — from a real employment firm, summarizing what HB 3773 requires, where the company's exposure sits, and what to do next. The HR Director read it. The General Counsel read it. Then it went into a folder.

Six months later, here's the conversation we keep having: "We have the memo. We just haven't done anything with it. Where do we even start?"

Why the memo stalls

The memo is built for legal interpretation, not operational execution. It tells you what the statute requires. It doesn't:

• Inventory every AI-touched workflow in your company
• Draft your candidate and employee notices
• Convert "you should have a policy" into a board-ready policy
• Document vendor diligence on the seven HR-tech vendors you actually use
• Train your team on the new workflow
• Assemble the dated artifacts you'd hand over under a demand letter

All of that is operational. It falls to HR. HR is already running at 110% capacity. So it doesn't get done.

What "implementation" actually means

Turning the memo into a defensible file is the work between "we know the rules" and "we can prove we followed them." It has six components:

1. AI Inventory & Risk Map — every system, vendor, and workflow that uses AI in an employment decision, mapped and risk-rated. This is where the entire file is grounded.
2. Candidate & Employee Notices — the disclosures HB 3773 requires, drafted to fit your actual AI use, ready to deploy. See the notice requirement deep-dive.
3. AI Use Policy — an internal policy written to be adopted by HR, IT, and management, not shelved by Legal.
4. Vendor Due Diligence File — documented review of each AI-touching HR vendor's compliance posture. Here's how to do it.
5. HR Team Training — a focused session so the people running the workflow understand the new rules and the new process.
6. Assembled compliance file — everything dated, organized, and built to survive examination.

What your employment attorney should and shouldn't own

Your employment attorney should own legal interpretation, case-specific advice, and any litigation response. They typically shouldn't own the operational build, for three reasons: it's not the work they're priced for, it's not the workflow they specialize in, and billing implementation work at attorney rates is expensive and slow. A focused implementation engagement at a fixed fee is faster and more economical.

How we work alongside counsel

We're not a law firm. We don't replace your employment attorney. We take the memo your attorney wrote, hand it back as a complete operational file, and coordinate with counsel on the questions that genuinely require legal interpretation. Many of our engagements start with a referral from the firm that wrote the memo.

The fast path from memo to file

Our 90-day Compliance Engagement takes you from "we have the memo" to "here is our dated, defensible HB 3773 file." Fixed price, fixed timeline, no billable-hour roulette. Or book a 20-minute Risk Review to talk through where your real exposure sits before committing to a full engagement.

Lakeshore is a compliance consultancy, not a law firm. This article is general information and not legal advice.