The Esquenazi Appeal: A Sales Perspective

The Esquenazi Appeal: A Sales Perspective

I use the picture above as a symbol to ask a question: If one of these individuals represents an “instrumentality” as defined and affirmed by the FCPA and Federal Appeals Court (respectively), and the other does not, should it make a difference to an anti-bribery program?  The basis for this post is  the Federal Appeals(…)

Rationalizing Bribery: Corruption Has No Witness.

Rationalizing Bribery: Corruption Has No Witness.

This is part three of my four part series on how I “Rationalized Bribery.”  It addresses the reality that there are usually no witnesses to overseas discussions involving an actual or potentially corrupt transaction.   As tweeted by Ben DiPietro, Wall Street Journal Reporter,  @BenDiPietro1 during my interview with Wall Street Journal Reporter Chris Matthews at(…)

Corruption: A Lesson for Tomorrow’s Professionals

Corruption: A Lesson for Tomorrow’s Professionals

  Guest speaking on May 6, 2014 at Fordham University. “Contemporary Issues in Forensic Accounting.” I shared with the students my reflections on international sales, both before and during cooperation, and detailed my thought process as to how I “rationalized bribery.” My hope is that by sharing my perspective with tomorrow’s business professionals, that they might(…)

Rationalizing Risk: Compliance as “Bonus Prevention”

Rationalizing Risk: Compliance as “Bonus Prevention”

As part of my series on “Rationalizing Bribery,” I now turn to the issue of personal incentive compensation. As tweeted by Ben DiPietro, @BenDiPietro1, Wall Street Journal Reporter, during my interview at the Dow Jones Global Compliance Symposium (DJGCS) on April 23, 2014 “I knew (what) I was doing was wrong but rationalized the risk.” I(…)