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 […]

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Benchmarking Bribery and Corruption: “Vet it and forget it.”

On my own “must read” stack has been sitting the “2014 Anti-Bribery and Corruption Benchmarking Report, Untangling the Web of Risk and Compliance,” (“ABC Report”) by Kroll and Compliance Week.  While I have read a multitude of bribery and corruption enforcement summaries, mostly published by law and audit firms, this was my first read of […]

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Excellence in Anti-Corruption Compliance Day

On June 23rd, 2014, I had an opportunity to participate in “Excellence in Anti-Corruption Compliance Day” as hosted by Ethic Intelligence. While my participation was via video-feed, where I  lead a presentation and follow up Q and A session on “Rationalizing bribery: Confronting corruption in the front line of sales,”  I have recently read a number […]

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The C-Suite Crucible and International Business: “Motivated Blindness”

In the June 2013 issue of Business Compliance (Baltzer Science Publisher, Anthony Smith-Meyer, Editor), Scott Killingsworth (Partner, Bryan Cave LLP) writes about “Ethics in the Executive Suite: The Best, The Brightest and a Wicked Problem.”* The work is the first part of a two part series, and my focus is on part one “The C-Suite […]

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How To Pay A Bribe: Solutions that Explode

Over the past few weeks I have had a chance to read How To Pay A Bribe, Thinking Like a Criminal to Thwart Bribery Schemes (2014, edited by Alexandra Wrage, Seven Wirz), and while I have enjoyed a number of the chapters, including those by Andrew Feintsein and Matteson Ellis (which is the subject for this post), […]

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Deterrence: You had me at “being caught.”

At my sentencing hearing, Judge Richard Leon stated that he had no doubt that I had been ultimately deterred, and added “Have you made a turn in the road for the better? There is no question about that either. But I have to be concerned about others, others out there right now who are aware […]

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A Presentation to Compliance Professionals: Rationalization Not Justification

On Thursday June 12, 2014, I was asked by Mike Kenealy (FCPA IntegrityCOO) & Craig Chadwick (Global Secure Summit) to address a group of Compliance Professionals from the financial sector in NYC. In my presentation, I shared my experiences from the field of international sales, including encountering foreign bribery, cooperation, and finally, my perspective on current compliance challenges. A […]

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Is Anti-Corruption a Business or Legal Issue?

Used with permission from Mak Yuen Teen On June 5, 2014,  Philippe Montigny, President of Ethic Intelligence (www.ethic-intelligence.com) asks exactly that question in an editorial (here).  My own perspective of compliance remains much along the lines of those such as Mr. Montigny and that of Professor Mak Yuen Teen (National University of Singapore), whose article […]

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