Monthly Archives: August 2014

EY Global Fraud Survey: “Depressing,” yes, surprising, no.

EY Global Fraud Survey: “Depressing,” yes, surprising, no.

In an August 21, 2014 post on the Network GRC Blog, concerning the Ernst and Young (EY) 12th Global Fraud Survey (link here for EY download), Cindy Knezevich  (Vice President of Marketing Operations at The Network), states, “it’s shocking how little headway our efforts are making in preventing global fraud.” The EY Survey, as Ms. Knezevich describes, is “well done and well-written.” Furthermore, EY does a great service to the international business community by calling attention to the dynamic that in lucrative markets with potential for rapid economic expansion “growth and ethical business conduct can sometimes appear to be competing priorities.” As the Survey well states, “with fewer remaining opportunities for cost-cutting, many businesses are now focused on opportunities in rapid growth markets.” From the front lines of international  business, that is exactly where the challenge and confrontation with risk exists.

As we all know, methodologies and findings from surveys can often be suspect, based on the pool of participants, how questions are asked, etc. However, the EY Survey, based on more than 1,700 interviews of “chief financial officers, heads of legal, compliance, risk and audit,” and conducted in 43 countries, is one of the most comprehensive corruption studies that I can recall, and it makes a great companion to the recent Kroll and Compliance Week report on which I recently reviewed. Nonetheless,  I hope that by sharing my own experiences, with the Survey as a companion guide, that I can help to add value to EY’s goal of contributing to “the ongoing conversation on these important topics.”

A shocker to some

The big shocker to some, but not to me, is presented in the Executive Summary, as 15% of CFO respondents are “willing to make cash payments to win business.” In addition, the survey found that a greater proportion of executives, including CFOs “expressed an increased willingness to misstate financial performance.” As to foreign corruption, more specifically, 20% of the respondents “do not recognize that new markets bring new risks,” and “44% of respondents report that background checks (on third parties) were not being performed.” Finally, as to training, only 46% of all CFOs attended anti-bribery and compliance training. Ouch.

As to the Board of Directors, which are tasked with governance over risk and audit “according to our respondents, they are sometimes seen as out of touch with conditions on the ground.” When that dynamic gets combined with the finding that “a significant global minority of one in five respondents do not recognize that new markets bring new risk,” one can see why many multinationals are running into troubles in growth markets. If the C-Suite does not recognize corruption risk in low integrity regions, and the Boards are “out of touch,” who is asking the “how are we making such aggressive targets in such high risk areas?” In such cases, as I have shared before, its all “high fives” when those quarterly numbers roll in to management.

With respect to Third Parties, the Survey sheds more light on the recent Kroll and Compliance Week “2014 ABC Report” that “third parties continue to vex compliance officers.” As the Survey states “the apparent lack of knowledge held by companies about the third parties they deal with is a real problem.” In fact, the Survey found that “only 59% of respondents report using an approved supplier database- a worrying low uptake for a simple mechanism.” In addition, “only 45% of respondents identified audit rights or regular audits of the third party as a process in place to monitor the relationship.”

The Section “CFOs in the spotlight,” is both troublesome and again, not surprising. As previously stated, “15% of CFO’s surveyed would be willing to make cash payments to win or retain business…and 16% of CFO respondents do not know that their company can be held labile for the actions of third-party agents.” Maybe those respondents should read and re-read the recent interview with Chuck Duross, former deputy chief of the Fraud Section in the Criminal Division of the U.S. Department of Justice, and whom I met while I was preparing for trial testimony, when he states that “if a company’s employees are aware that the distributor is paying (or just offering) bribes to government officials to help sell the product, the company and its employees could be criminally liable as conspirators and aiders and abettors.”

Help me here, but in public companies don’t CFOs (along with the CEO and the Board) sign 10Ks (SEC) that acknowledge responsibility for controls over fraud prevention and detection? And as to the boards and audit committees that are tasked with governance, “52% of c-suite interviewees think that the board needs a more detailed understanding of the business if it is to be an effective safeguard against fraud or corrupt practices.” All of this results, in the opinion of the Survey authors, with a “tick the box” approach to managing risk.”

I have spent a great deal of time sharing the view from the front lines of international business that all too often field personnel are left to ponder “what does management really want, compliance or sales?” What the Survey demonstrates, in a way that is compelling and hard to dispute, is that at the C-Suite level, corruption is all too often ignored, not understood, or, as the Survey identifies, tolerated and supported. Like the trajectory of a stray bullet (sorry, I come from the Defense Sector), which drifts further from target as it travels, the messages of anti-bribery compliance from a c-suite and board that doesn’t understand it, will not gain clarity as it travels down through an organization.

My top two reasons to be “depressed”

I have to agree with Ms. Knezevich, in her own view that there are “three conclusion that I found downright depressing,” but in my own experience, not at all surprising (here are my top two):

1. “Rising Economical Risks and Slipping Ethical Standards.” The rising search for new business opportunities in lucrative yet low integrity markets leads to “slipping ethical standards.” In those areas, where there are weak state institutions (hello again, Matt Ellis), infinite demands for “small bribes” (see Transparency International Report), yet plenty of short-term business up for grabs, a “win-big, lose-big” mentality takes hold at the front line. Where you have financial incentives indexed to those wins: Peril for all.

2. “Weak controls, Failure to Follow Through on Tone from the Top.” I am with Ms. Knezevich all the way on her conclusion, that “inauthentic leadership that talks the anti-bribery talk but then doesn’t back it up with a solid program for employees is creating a very dangerous situation.” I remember exchanging perspectives with a colleague on anti-bribery programs, and asked him what his leadership was providing (he worked in a public company). He shared with me that his CEO told him “win the business but keep us off the front page of the Wall Street Journal.” Mixed message?

I conclude again applauding the EY Survey, its findings and conclusions as elevating our understanding of how corruption and fraud exists among the corporate environment. While some might attribute all this to “institutional fatigue about anti-corruption initiatives,” my experience points to the Survey’s findings that in wanting to secure “revenues in rapid-growth markets,” corporations are willing to blast out both anti-bribery messages while ignoring or tolerating corrupt activities in order to “win above all else.” So, I will leave in agreement with Ernst and Young that “much remains to be done.”

Bribery & Deterrence: A Tale of Two Sentences

Bribery & Deterrence: A Tale of Two Sentences

In an August 11, 2014  article ( “Supersize me: Innospec 4 sentencing remarks do much more than they say on the tin,” Barry Vitou &
 Richard Kovalevsky (“The Authors”) do a great service by elevating the remarks of Judge Andrew Goymer at the August 4, 2014 sentencing hearing of the four Innospec defendants.* Inasmuch as the sentencing of individuals is an integral component of deterring others from engaging in corrupt behavior, it is important to focus not only on the sentences, but on the statements by sentencing Judges which accompany the pronouncements of months and years. The Authors did just that, and from my perspective, those judicial declarations, combined with the actual sentences, are what collectively form the messages being sent to business entities and their executives, including those who work and operate on the international front lines.

Accordingly, as I read the article by Mr. Vitou and Mr. Kovalevsky, along with the referenced remarks from Judge Goymer, I could not help but reflect on the comments and messages from my own sentencing hearing. While no two cases are alike, and there are considerable and noteworthy differences between the Innospec case and my own, not to mention two distinct regulatory, enforcement and judicial environments (even if based on common traditions), I prefer to focus those judicial messages which I see as shared in both courtrooms. However, it is not for me to speculate or represent that I understand the background or judicial thinking that went into these sentences, so my post here is only from the perspective of one who was sentenced.

My own impression of sentencing is that a Judge speaks not only to the defendant, but also, in the context of these corruption cases, to the wider audience of the international business community. Thus, judicial messages incorporating deterrence do not resonate without awareness. Accordingly, I hope that this post might bring some value to those on the front line of international business through a continued focus on the personal consequences of corruption and bribery.

The Direction of Travel

To start, I agree with The Authors in that “these sentences highlight that the direction of travel when it comes to the punishment to be meted out to those found guilty of bribery offenses is that they will be tougher.” As Mike Volkov stated in a recent blog post “We know that FCPA enforcement is here to stay – not even the Chamber of Commerce can slow it down.” It is also interesting to note The Authors’ remarks that with respect to the UK, Judge Goymer referenced prior rulings that “fines against companies and corruption offences should be of a similar scale to those imposed…in the United States.” Thus, perhaps even if not in a formal sense, recent UK-US anti-bribery enforcement measures are being harmonized to deliver the same message to multinationals and international business personnel: beware.

As Judge Goymer stated “decisions are made by human minds. It follows that those high up in the company should bear a heavy responsibility under the criminal law.” While Judge Goymer spent a great deal of time discussing the social harm caused by corruption, much due to the consequences of the Innospec bribes (see my post on the “Illusion of how bribery has no victims”), and the “effect on the community,” I perceive great similarities in how both Judge Goymer and my own sentencing Judge (Judge Richard Leon, US District Court, District of Columbia) addressed the issues of corruption and accepting responsibility.

Judge Goymer said at the sentencing of Mr. Jennings that “by pleading guilty, he accepts he knew and intended to be a part of the corruption.” With respect to Turner, “he accepts he had an active part in it (corruption) in Indonesia and Iraq.” As to my own behavior, Judge Leon referenced conduct that was “really bad by your (my) own admission.” Interestingly, both Judges weighed and called attention to the value of honest courtroom testimony as part of cooperating. With respect to Turner’s testimony, Judge Goymer noted “his evidence was not challenged on honesty but only on the accuracy of detail,” and for my own testimony, Judge Leon stated, “the Court was very mindful of your candor there. You were cross-examined vigorously by some of the finest lawyers in the country…”

Deterrence and Incentives

Reading the sentencing remarks in the UK, and re-reading my own, it would appear that both Judges addressed the concepts of inducements to cooperate as well as deterrence by incarceration. While the sentences were different, that is less relevant to the importance of the judicial pronouncements. As Judge Goymer stated “just as it is appropriate to sentence as a deterrent, it is also appropriate to encourage others to cooperate.” From my perspective, a sentence reduction accomplishes both.

Judge Goymer said “it is necessary to give encouragement to those involved in serious crime to cooperate with authorities,” while Judge Leon emphasized that others need to be concerned “that even if they are caught, and even if they cooperate, they are going to do jail time because in this arena, that is the ultimate deterrence.” Do those sound like dissimilar messages? Not to me. From my reading, each Judge is weighing in, albeit differently, on the same challenge: the personal consequences of corruption and the judicial value of accepting responsibility.

Judge Gaynor seems to focus on the importance of inducements, and Judge Leon, deterrence, but again, I see those issues as representing two sides of the same dynamic: what is the judicial weight of accepting responsibility against the consequences of overseas bribery and other corrupt conduct? On both sides of the Atlantic, the net effect was one of mitigation. While I am sure that Mr. Turner is grateful that he “narrowly indeed escaped going to prison,” and that Mr. Jennings, particularly, like myself, is greatly appreciative that his loss of liberty will be of a shorter duration due to his cooperation, I would still hope to keep the issue of deterrence elevated through these sentences.

As a UK appeals court stated, “the solitary incentive to encourage co-operation is provided by a reduced sentence following a guilty plea,” but one does not feel so fortunate once inside a correctional facility, so take note. The loss of liberty, even for a reduced time, has a significant impact on one’s life, inclusive of family and loved ones. Thus, for those on the front line of international business, you can take my own experience through fourteen and a half-months of incarceration as a strong message of deterrence, even in the context of cooperation, or better perhaps to listen to Mr. Vitou and Kovalevsky, “You have been warned!”

* My title might be somewhat misleading as it is really not two sentences. I was counting the Innospec four, metaphorically, as one sentence, given that it was one hearing. Also, my apologies up front if my description of UK legal and judicial proper names, titles, etc., is culturally and/or linguistically incorrect. Having lived in the UK for a year, I did get an appreciation of the concept of “two nations divided by a common language” but not necessarily in the lexicon of lawyers, judges and regulators (at least not at that point in time).
Corruption, Regime Change & Risk

Corruption, Regime Change & Risk

Recently, I have been reading and blogging on a number of different papers, guides and articles that deal with the challenges of foreign bribery and third party intermediaries. While each work has been interesting, compelling and relevant, there are some common elements that warrant further discussion. One such issue which presents a difficult challenge from a number of anti-bribery perspectives is the issue of regime change, and how governmental turnover impacts the long-term assessment and vetting of third parties, specifically, governmental intermediaries.

The issue of governmental turnover can be evolutionary or revolutionary, with a continuum of variations; however, regardless of how a regime might “change hands,” the potential impact on a third party in terms of corruption, is quite similar. As the recent Kroll and Compliance Week “2014 Anti-Bribery and Corruption Benchmarking Report,” states, “taming third-party risks continues to be a major weakness for anti-corruption programs, and the problem may well be getting worse.” * Furthermore, when you analyze the impact of regime change as a potential hazard in third party assessment and long term monitoring, the challenges become even more complicated.

Why would regime change present a risk factor?

Broadly, regime change can be a turnover in government, from an orderly transition through a democratically elected leader and party, to violent revolution, and all the permutations in between. However, when discussing regime change in the context of foreign bribery, I think of countries that experience regime change and where the institutions of purchasing and decision-making are weak.

As Mr. Matteson Ellis states, in such cases “the lack of credible institutions can encourage impunity,” and “bribery thrives when there are not effective institutions to expose, investigate, judge and penalize it.”** It reminds me of a conversation I had with someone who was sharing the struggles of doing business in a South American country due to the formation of a “corruption commission.” When I asked how he was going to deal with such a commission, he answered “through corruption.” Yes, that is what he said!

So, what are the signs of weak state institutions in the context of regime change? I will start with Mr. Ellis (and thank him again for his thought contribution) who broadly defines them as those “which complicate the ability of governments to administer a wide variety of complex government regulations that apply to business.” I would also add the following:

  1. Where a majority of personnel who occupy civil positions throughout the bureaucracy are terminated and replaced post-regime change.
  1. Where the procurement process is suspended (temporarily or long-term) during regime change, and where purchases are either cancelled or stalled indefinitely. Transparency International (TI) has a very well defined chronology of procurement as planning, bidding, bid-evaluation and implementation and monitoring. *** When any of those four processes are haphazardly delayed or terminated, that is indicative of weak state institutions.
  1. Those places where personnel who are appointed to the ministries and the bureaucracies are not trained, are poorly compensated, and who have no background in their selected appointments, e.g. purchasing, inspecting, etc. As the TI guide states, “where procurement officials are poorly paid, badly trained or lacking a viable career path the risk of corruption increases.”
  1. Where the rules of procurement and the tender process are poorly defined, subject to haphazard change, and where there is a confusing protocol of “official” signatures that are required throughout the procurement process.
  1. Regions or countries where political change comes quickly, and there is not only a turn over in regime, but in the system of government, and this can take many forms. We can look at the recent regime changes in Libya, Egypt and the Ukraine, as examples of where prior state institutions are actually dissolved as new leaders seek to restructure the entire bureaucratic landscape.

Accordingly, when these trends exist, every time a regime changes, the procurement and staffiing process starts anew. In other words, procurements are stalled, existing orders are cancelled, new signatures are required, and recently appointed officials, who have little background or training in their field of appointment, are seated.

So, what does this mean for foreign bribery?

As Mr. Ellis describes, where you have an unstable state institutions combined with unclear and “complex regulatory regimes,” companies must often rely on “third party agents to get things done.” The challenge of regime turnover in this environment is that when a government changes hands and the institutions of state are weak, the nature of the relationship between a third party intermediary and appropriate governmental officials can dramatically change. Such new “connections,” affiliations, and interactions can present great peril for companies trying to maintain a compliant network of third parties relationships that provide a suite of legitimate business services.

It is about the touch points

When regimes with weak institutions change power, the touch points between an intermediary and government officials will also turn over as prior contacts are replaced with new “touch points” once new personnel are appointed. Thus, taken at the extreme, a properly vetted intermediary that has been providing legitimate business services during a prior regime might now have contacts in power that will work corruptly with that same intermediary in the new regime. Hence, the political and corporate exposure to corruption via the new public officials now changes the nature of those services from legitimate to corrupt, or perhaps both. While one might argue that a third party who goes from “legitimate to corrupt” should not have made it through the vetting process from the start (a valid observation), the possibility that an intermediary might change his position on the “continuum” of corruption due to regime turnover should be taken seriously.

I recall a conversation with a third party, doing little business at the time, and who referenced a “just wait” mentality, stating that once the opposition took power in a few months, newly formed corrupt relationships would bring results. He said that the new procurement officials, upon taking their place in the bureacracy, understood that “they only had only have a few years to make their pension.” In other words, a change in regime can dramatically increase corruption risk, with the potential consequence that today’s “clean” intermediary could become tomorrow’s “corrupt” one, as new governmental relationships comes into play with respect to future business and transactions.

Thus, bribery risk is not necessarily a constant in the life of a relationship with an intermediary.  What this all means for a corporation, is to avoid surprise. As a number of compliance practitioners discuss, vetting and assessing is a long-term enterprise, and the re-vetting or periodic audit of existing third party relationships is critical. Where you have a country with a poor reputation for integrity, a volatile political system, and with weak state institutions, an automatic re-assessment of third party intermediaries as triggered by regime change, would seem to be a strong guard against future corruption risk. Regime change in such cases can be a perfect storm of corruption, and as Mel Glapion, Managing Director, Kroll, stated in their report, in such cases, companies might want to consider“sharpening the saw, and improving the processes and measuring that information that’s coming back to you.”  I would only add, do it often.

  • Kroll and Compliance Week “2014 Anti-Bribery and Corruption Benchmarking Report, Untangling the Web of Risk and Compliance,” 2014copyright Kroll and Compliance Week.
  • ** in How to Pay a Bribe (2014, edition, Edited by Wrage, Wirz, Copyright, Wrage, Alexandra Addison), chapter by Ellis, “Regional Flavor: Crosscutting Corruption Issues in Latin America.” Mr. Ellis is Special Counsel to Miller and Chevalier.
  • *** “Curbing Corruption in Public procurement, A Practical Guide,” 2014, Transparency International.
  • Copyright for illustration belongs to Richard T. Bistrong


Corruption & Procurement: Bribery “Thrives in the Dark.”

Corruption & Procurement: Bribery “Thrives in the Dark.”

In the July 31, 2014 edition of the Jakarta Post there was a featured article “Smith & Wesson bribery scandal involves National 
Police officers,” which reported that  “the Indonesian Corruption Watch (ICW) has called for an investigation into an alleged attempt by US gun-maker Smith & Wesson to bribe officials at the National Police.” Such civil group investigations into the “demand” side of bribery is very relevant to a recent paper by
 Transparency International (TI) called  “Curbing Corruption in Public Procurement, A Practical Guide.” The TI paper, as stated in the on-line brief, “provides government officials, businesses and civil society with a practical introduction to the risks of corruption in public procurement.”

In addition, the report “outlines key principles and minimum standards which, when respected, can protect public contracting from corruption.” In my experience and opinion,the Guide goes well beyond that scope, and is an incredibly reflective representation of corruption risks that are prevalent in international public procurement. Thus, I hope that my comments, where I reflect on my encounters with such corruption, might lend additional value to this already compelling work through the elevation of real world examples and perspectives.

As the report states in the introduction “few government activities create greater temptations or offer more opportunities for corruption than public sector corruption,” and the OECD estimates that “corruption amounts to between 20 per cent and 25 percent of the procurement budget.” Thus, procurement corruption is a problem and dynamic that exists both on paper and in reality, and as the OECD points out, on a massive scale.  While the TI paper does an excellent job of breaking down public procurement into four chronological stages, what I found resonating was the description of how there is a continuum of corruption in terms of level and scale. The report speaks of corruption by “low and mid-level public officials” (see prior post on TI paper “Countering Small Bribes”) and “corrupt acts committed at a high level of government.”

The guide also calls attention to subtle forms of corruption that are used to “manipulate budget allocations and project selection, even before the contracting process begins.” Indeed, as the report calls out, such activities occur “through the manipulation of eligibility criteria in the tender documents, or having technical specifications that are biased and without merit.” That description reminded me of a tender in the Middle East whereby the delivery period as stated in the specification was prohibitively short, as getting the necessary regulatory licenses after award would actually burn through through the entire delivery period.  It was a requirement to which adherence would be impossible, or so I thought.

Hello I must be going

I travelled to the Middle East to meet with the procurement chief (this was a substantial tender) and to see if this requirement could be changed as to allow for a reasonable delivery period “after regulatory licenses” were secured. In non-procurement speak, I was asking for a delivery period that would be fair to all bidders, as no vendor could control how long it would take to get a license.  Well, as I sat there professing the need for a modification, I noticed that on the chief’s desk was the approved and signed license for the competitor, who was also the incumbent supplier. To get that license, the competitor needed the end-user signature (being the person to whom I was speaking), and that would have occurred three to four month prior. Thus, needing no translator, and understanding what I was facing, I finished my coffee, thanked the procurement official for his time, and departed.

That is but one example of a public tender where one entity knew via corruption that it was going to receive an award, and the procurement authority used a restrictive delivery period as called forth in the tender document, to guarantee the result. It takes two to corrupt, and I hope this example demonstrates how both the supply and demand side work together to get a desired outcome, as the Guide states “even before the contracting process begins.” While I don’t know if a bribe was paid in my Middle East example, does it really matter, as the process itself was corrupted?

 Small Island, big purchase

The report talks of the “Financial Impact” of corruption, as “burdening a government with financial obligations for purchases or investments that are oversized, not needed or not economically justified.”  This is a very real and serious issue, and I have seen numerous examples of needless and wasteful purchases, some of which were designed to facilitate corrupt transactions (sometimes it was just disorganization and the output of inefficient procurement processes and personnel).  Either way, such procurements do not facilitate the public good through the acquisition of products and services that are needed by governments and hence, serve the well being of the citizenry.  I recall one story of a small island nation with an outgoing leader who started a buying binge prior to his departure from office. During that time period, there was a large procurement of  defense product, far beyond what the tiny island could have needed for domestic security, and I remember asking the sales manager, “what are they going to do with all that stuff?”

I didn’t really need an answer, I knew this was wrong,  and my question was rhetorical as part of my own rationalization process.  It was certainly clear to me that the purpose of that procurement had nothing to do with domestic security and it was nothing but an unnecessary purchase with corrupt intent under the “umbrella” of public safety.  A very telling example, and as the report states, these are funds that “could be used to provide or improve essential amenities and services” as opposed to facilitating corruption for personal financial benefit.


The paper sets out a number of principles that “minimize corruption risk” in the procurement process, and a number of them resonated with me in the context of my own experience but the one that caught my attention was professionalism.  As the report states, “where procurement officials are poorly paid, badly trained or lacking a viable career path the risk of corruption increases.” Here we have a dangerous dynamic from the perspective of trying to change corrupt procurement environments. As Mr. Matteson Ellis states “when low-level government officials are not paid enough, they sometimes rationalize seeking rent by other means.”*

Making their Pension

Where you add regime change, which brings in a new group of procurement officials, it is a recipe for procurement corruption on a number of levels. After these new procurement officials get seated, they may aggressively seek bribes knowing their employment might be of limited term due to the next changeover (as with their predecessors).  I remember one such instance, post regime change, where an intermediary shared how there was going to be a series of procurements, as new officials knew that they only had a few years “to make their pension.” Accordingly, in such regions where you have low paid officials, high turnover due to regime change, and a lack of training, I see few solutions to this corruption spiral.  As described by Mr. Ellis, in such regions with weak state institutions,  “bribe requests might be baked into the economic order.”

Like the sales person on the front line of international business who may be looking at a pay check that speaks to “win above all else,” for the procurement official who sees nothing but opportunity to supplement what might be a meager state pay-check, both sides now look at corruption as win-win.  Small bribe or big bribe, this is a dangerous dance for all involved.

Corruption in the Dark

As the report states, “corruption thrives in the dark,” and “lack of information on governmental activity and decision making can easily hide corrupt manipulation of decisions in a procurement process.” So what can be done? Well, until governments seek to address the issues of training, compensation and turnover with respect to procurement organizations and personnel, perhaps the part of the TI Paper called “Checklist for Government Officials,” (page 21, 3.2.) should be reviewed. This is a critical section which was designed to highlight red-flags “about the integrity of the process,” and which might also be a suitable guide for multinationals. In other words, where those inherent procurement red-flags exist within a region, country, or ministry, perhaps the corporation is well advised to “stay-away” until those built-in institutional perils are addressed and changed.

Accordingly, we are left with organizations such as Transparency International and those like the Indonesian Corruption Watch, who are not going to let the issue of bribery remain solely with the regulators at the individual and corporate level. In my experience, corruption risk needs to be addressed through a continued focus on international public procurements, as this is where the “demand” side of corruption exists. My complements to TI for publishing the Guide on Procurement; I found it surprisingly reflective of the realities “on the ground” of international business.

* in How to Pay a Bribe  “Regional Flavor: Crosscutting Corruption Issues in Latin America,” which makes a very relevant companion guide to the TI piece.