I recently had the honor of being named to Compliance Week’s list of Top Minds for 2017, earning the title of “The Great Communicator” from Bill Coffin, Donna Rice, and the CW team. If you had told me in 2012, when I was sentenced to a Federal Prison Camp as part of a Plea Agreement for violating the FCPA, that five years later I’d be telling my story to E&C professionals around the world, and helping them to better calibrate real-world risks into their compliance and business practices, well, I would have found that hard to believe. Nevertheless, here we are. The Top Minds interview with myself and Bill Coffin, editor-in-chief, Compliance Week, can be found here.
In April, I visited Amsterdam, for the first time in over a decade, to talk about bribery in the country where I bribed, and over the course of this year, I’ll continue my travels to connect and collaborate with the ethics and compliance community. The opportunity to now communicate with business and compliance leaders from around the world makes me think back to the winter of 2016, when I met Sean Freidlin from SAI Global, for lunch in New York, not far from where we both grew up. During our lunch, we shared perspectives and I spoke to him about my experiences with bribery, corruption, ethics, and compliance.
Over the course of two hours and a gluten free meal, we discussed how doing the wrong thing, and getting caught by US and UK law enforcement, changed my life. I shared my experience relating to the risks of working with third parties in foreign countries, the psychology behind some of my decisions, the shift from rules-based to values-based compliance programs, and how compliance officers can help their employees when confronted with difficult situations like the ones I had experienced.
Below, you’ll find an excerpt from our interview. If you’re interested in reading the full interview, you can download a free PDF copy of our conversation here.
SF: Do you consider yourself a good person?
RB: I do now, but I didn’t in 2007. There was a time, particularly when I was in my family business, when I had a good family life, but years later, due to no one’s fault but my own, I chose a path which ultimately ended up causing tremendous ruin, for myself, and my loved one’s. The dynamic of ‘win above all else’ took priority above all else, including family and spirituality. Today, I am grateful to have those bonds back in my life, and to enjoy the fellowship, friendship, and camaraderie of compliance professionals from around the globe.
But wherever my career and journey might take me, I will never again disconnect from the networks of those who care about me and my well-being. And I, theirs. That’s something I talk about often.
Today, more than ever, technology makes it easier for people to stay close to their personal networks.
For commercial teams who might read this, if you’re jet-lagged, sleep deprived, and struggling with an ethical or business decision far away from home – call your family!
Listen to them, stay close to them, and remember, if you go tip the wrong way in ethical decision making, those are the voices that you will lose, and those are the lives which will be devastated as the result of your conduct. Skype, Facetime, or text, whatever it takes, but listen to those voices! Then get on the phone and call your manager and compliance leaders!
SF: Why do you think people don’t think they’ll get caught when they give or take bribes or act corrupt? How do you justify doing something wrong when you know it’s wrong?
RB: There’s something called optimism bias. You think that the probability of you getting caught is less than someone else getting caught. You think “it can’t happen to me.” The most dangerous part of optimism bias is that the longer you’re not caught, the more you think you’ll never get caught. So I was really thinking of myself as invincible. Always on the move. Nobody is ever going to catch up with me. I thought I was successful and safe, but what I wasn’t counting on or thinking about was one of my intermediaries getting caught.
To continue reading my interview with Sean Freidlin, download a PDF of our full conversation here. To learn more about the psychology behind bribery and corruption, read this whitepaper from SAI Global.