The higher purpose of FCPA compliance

Compliance officers and corporate anti-corruption lawyers can become quite versed in anti-corruption tools, laws, regulations, and resources. They can talk for hours about setting up hotlines for employees half way across the world, developing proper training programs on how to resist bribes, conducting due diligence, or defining what constitutes a foreign official under Foreign Corrupt Practices Act (FCPA).

Yet, in the midst of all these technical details and hundreds of pages of documents and forms, I often find that they are missing the bigger picture – why what they do actually matters. Why it matters not just for their companies and not just for complying with the law, but for the millions and millions of victims of corruption.

I was reminded of this late last year at Transparency International-USA Integrity Awards dinner. There, Mark Mendelsohn, one of the chief architects of increased FCPA enforcement in recent years, spoke of the need for the corporate anti-corruption professionals to keep in mind the real costs of corruption and why what they do actually matters, even thought most of the time they are “not confronted directly” by the tragedies of corruption. Check out his remarks, something you don’t often hear often from FCPA compliance specialists:

Mark, of course, is referring to these winners of TI’s Integrity Awards – Poddala Jayantha from Sri Lanka, Sergei Magnitsky from Russia, and Gregory Ngbwa Mintsa from Gabon. You should take the time and read their stories.

Published Date: January 25, 2011