I spent over a decade as an International Sales Vice-President, bribed foreign officials, covertly cooperated with international law enforcement, and went to prison. Having that experience behind me, I am now extremely grateful for the opportunity to share my real-world experience and perspective concerning compliance challenges which continue to exist at the front lines of international business. However, my path to getting to where I can now share that journey with others, was filled with many ups and downs. While I remain grateful that the worst part of this experience for myself and my family, including the loss of liberty, remain in the rear view mirror, I always manage to keep an eye on that mirror, as not to forget the path, and the humility, which brought me to my current work. As the CEO of Front-Line Anti-Bribery LLC, I now work with business, commercial, and compliance leadership, to assist and support those in the field who might face similar challenges, and to help calibrate compliance programs and practices to the real-world challenges which forward based teams face.
During the many years when I was working in the field of international sales, I was aware that I was engaging in illegal behavior. However, at that time in my life, I wasn’t thinking about getting caught and did not think I would get caught. I was well educated, well paid, and in a very respected position. So why break the law? Well, as I have shared, in my case, it was a perfect storm, where a number of factors came together, all which I talk about extensively in my presentations and writings.
When I did get caught in 2007 (by my former employer), it was a frightening moment, to say the least. I was alone facing a panel of attorneys and seasoned investigators. Of course, the first consequence that comes to mind in a situation like that is the loss of employment and income. It didn’t take long to calculate that I would be terminated in the near future, so I started thinking about the financial consequences to my family.
The second “getting caught” point for me was by far more significant. It was at this point that I truly hit bottom and started on my trajectory of rehabilitation, which continues to this day. It started in the spring of 2007 with a call from the Justice Department to my attorney, Brady Toensing. They said they knew about the investigation by my then, former employer, and they offered to let us come in and to talk about cooperating with the Justice Department. It is really difficult to articulate the intensity of that first meeting. But I realized, as described by DOJ Attorney Joey Lipton (at my sentencing), this was my “line in the sand.” No matter what happened up until that first meeting at the Justice Department, this was a chance to truly come clean with my misdeeds. For me, the process of cooperating with the government also allowed me to re-think how I had been living, and to start the healing process which continues with my family and friends.
My cooperation with US and UK law enforcement (I was also targeted by the UK for offenses which occurred while I was living in Manchester) lasted five years. That phase included almost three years of covert cooperation (one of the longest periods of covert cooperation in Federal Law Enforcement white-collar enforcement history) and two years of preparation for trial testimony and actual testimony, including three calendar weeks of grueling cross-examination. While there has been a great deal of reporting about my covert cooperation, and the outcome of the cases where I was a cooperator, it was ultimately Judge Richard Leon (District Judge, DC) who would weigh the value of my cooperation, and he would have sole authority to judge the significance my cooperation against the magnitude of my illegal conduct, which I candidly admitted to in my court testimony.
Judge Leon understood the seriousness of my illegal conduct, the value of my cooperation, as well as my personal and professional efforts to contribute to society since the ending of my covert cooperation. When he weighed all of that, which I think of as the “good, bad and ugly,” he decided that a sentence was still warranted. I am at peace with his decision, where he sentenced me to eighteen months, and I served my prison time with dignity, providing value to others in their educational goals, as both a tutor and English as a second language instructor.
As I now reflect, I realize how I lost sight of the importance of strong family and personal relationships during the years of conduct to which I pleaded guilty. My dedication to those bonds, which was once extremely strong in my life, had been replaced with the never-ending want and accumulation of material things. “Getting caught” by the government stopped that downward spiral in my life, and set me back on a course of reconnecting with what is truly important, and on a path of reconciliation. Thus, when I share my experience with others in my current work, both personally and professionally, I do my best to discuss the ups and downs of this crucible, so that people might understand that success built on a corrupt foundation is no success at all. My goal is to try to inspire leadership across the business to talk about, address, and mitigate the challenges of international business which can impact ethical conduct and behavior. We all face dilemmas in our lives and work, but if we share them, we can address and unpack them together, reducing the power and probability that they will lead to a ‘tipping point’ to the wrong side of ethical conduct, to everyone’s peril.