Richard Bistrong FCPA Blog

Richard Bistrong FCPA Blog

A Real World Compliance Blog based on the actual experiences and perspective of Richard T. Bistrong, a former international sales executive. A venue dedicated to the open and professional exchange of real-world FCPA compliance issues and challenges. Now at

Thursday, April 24, 2014

Rationalizing Bribery: A Perfect Storm from the Field of International Sales.

On April 23, 2014 I was interviewed by Chris Matthews, Wall Street Journal Reporter, at the Dow Jones Global Compliance Symposium, in a keynote interview entitled "Informing on Bribery." The session started by discussing elements of my cooperation with US law enforcement, including my disclosures to the Department of Justice and FBI concerning overseas corruption in which I had participated, as well as witnessed, during my career in international sales.  These initial disclosures, made during my proffer sessions at the Department of Justice, ultimately commenced my two and half years of covert cooperation with US and UK law enforcement. I addressed how the FBI witnessed, during my cooperation, the "wink and nod" language of foreign bribery, as confirmed by my first consensually monitored conversation in July of 2007.

Mr. Matthews then turned the questioning towards "what was I thinking" as I encountered corruption in my overseas work. My initial response to his question was that it was a "perfect storm of rationalizing risk," which I broke down into four elements:

1. International procurement instability.

2. Personal incentive compensation.

3. Lack of witnesses.

4. Illusion of no-victims.

Over the next week, I will post on each one of these factors, which all contributed to my "rationalization" of bribery as I encountered it during my international sales experience. To be clear, I make these observations in no way to "justify" my behavior, or even to "explain it away." To the contrary, my goal here is to open the window with respect to my thinking and how I rationalized overseas corruption. My hope is that by sharing my experience, compliance professionals and practitioners might better understand the forces facing international executives, and to better assist them with the  tools and training to help them manage the risk they face, especially the front line personnel, who are, in my experience, the most exposed to foreign corruption in their work. As Wall Street Journal Reporter, Ben DiPietro, tweeted during the interview "I knew (what) I was doing was wrong but I rationalized my risk." Well, here's how:

International Procurement Instability. Winner Take All or Win Big-Lose Big.

Having spent about half my career (the first half) as a VP responsible for US law enforcement and US military sales, I could easily describe that procurement environment as stable. As I shared with Mr. Matthews, take a fifty mile radius around Washington DC and consider all of the surrounding federal, state and local agencies, each one of which has a procurement department(s). These procurement agencies all purchase goods and services on a regular basis. It does not matter if there is a change in departmental leadership, a new President, a new Mayor, etc, the purchases continue. If a procurement official goes on vacation, takes leave, retires, etc, there is someone to take his or her place in the bureaucracy. In addition, the frequency of purchases ranges from long sales cycles (as in large military contracts), to smaller, high-frequency purchases. For a sales person, this is a stable environment and one which can easily be modeled into a sales forecast. If a sale is lost to a competitor, there will be another agency to go after, or that same agency will be buying again in the near future.

Contrast that environment to overseas procurement, regardless of product or services. In many countries, including EU and NATO members, the Ministries at the national level procure goods and services for the entire country, from the federal to local level in a single integrated contract. Thus, in those countries, the contracting entity is concentrated in a specific national Ministry, be it Health, Finance, Interior, Defense, etc.  In addition, those contracts, which cover the purchases for the entire country, often have renewal and escalation clauses which reduce the probability that they will be offered again for public tender in the near future. In my experience, it was common for a Ministry of Defense or Interior to award a contract and to use renewal clauses over the course of three or four years.

So, How Does that Impact an International Sales Executive?

It means that in a territory there will be a small number of tenders for the products/services that he or she sells, and that those tenders will be significant in value. In addition, if the sales person "loses" the tender to the competition, it means that in terms of the identified market segment, there will be no more business opportunities, perhaps, for years to come.  Thus, for the sales person, and for the company, in most overseas countries, it is "win big or lose big" for sales to state controlled entities.

Is That All?

No. Moving outside the NATO and EU community, procurement instability gets dramatically magnified. In addition to the infrequency of tenders and their large financial scope, there is also the unpredictable and unstable nature of the procurement process as a stand alone issue. Such instability, which can stall, delay, indefinitely postpone, or even cancel a procurement, can be attributable to the following issues which I have encountered the most:
  • Regime Change  and Personnel Turnover. I list this bullet point first as it is probably the most common reason for procurement delay or cancellation. In many countries, a change in regime can cause a cancellation and re-bid of all outstanding tenders in the State Ministries. In addition, where there is not cancellation, many of the tenders, even those awarded, will be indefinitely delayed, as existing procurement personnel are often replaced. Such turnover in procurement staffing due to regime change is common. In extreme cases, the funding for all outstanding procurements is cancelled, and the entire tender and sales process starts from the beginning. 

I recalled a transaction in my interview where I had sales responsibility for a  procurement which was funded and licensed, yet delayed for over a year, due to regime change. The change in leadership had caused a significant turnover of personnel in the Ministry, and one of the people who needed to sign the final release of the purchase order was no longer employed  and had to be replaced. One year for a single signature: how can you account for that kind of instability in a sales forecast? 

  • Logistics. In many countries, even after a purchase order is funded, signed and issued there can be indefinite delays due to licenses (if regulatory agencies are involved) and/or the arrangement and costs of logistics, including warehousing, shipping and forwarding.  I was involved in a transaction where the purchase order was executed, funded and secured, but there was a negotiation over which party would pay and arrange for the transportation costs once the goods had arrived in port, including storage fees. That negotiation lasted almost six months, mostly driven by the end user (who was a public official). Again, circumstances beyond the control of an international sales person, but one which makes for instability in the planning and forecasting process, both on the personal (as in bonus compensation) and corporate level.

What Does This Have to do with Rationalization of Bribery?

A lot. This is the procurement environment in which overseas sales, marketing and business development people operate. Infrequent but large volume tenders, delays subject to regime change, personnel turnover and logistics, all of which make the entire sales process extremely unstable. If we are talking about sales personnel with high personal performance sales goals as part of their incentive compensation (the next part of this storm), creates tremendous pressure, as it becomes difficult to predict and achieve performance goals.  In other words, the sales person starts to think, "if I miss this sale, I doubt I will see this opportunity again any time soon,  and even if I do win  it, I don't know when it will actually be booked and shipped. A miss here will destroy both my forecast and bonus."

If we are talking about a public company environment, the challenge gets dramatically magnified, as sales and expense forecasting, which are usually on a rolling and quarterly basis, are a part of corporate life. Nonetheless, how can you forecast for a "win all-lose all" tender? How can you predict when an order will get shipped and billed when it is subject to all kinds of delays due to regime change, personnel turnover, etc? All this makes for vulnerability if a corrupt offer is presented. Accordingly, this backdrop of procurement instability is a major part of the "rationalization process," even if mostly an unseen one.

More to come.

Monday, April 21, 2014

GSK, "Free Samples," and a New Business Model.

On April 16th, 2014 Hester Plumridge and Christopher M. Matthews, Wall Street Journal, reported that GlaxoSmithKline (GSK) is investigating claims that its employees bribed doctors "in Jordan and Lebanon by offering perks such as flexible travel arrangements and free samples that doctors could sell on..." (for the full article, link here).  GSK, as reported in the article, stated that the allegations "relate to a small number of individuals in these countries." In their press release of 16 April, 2014 "GSK Statement on Media Reports," (link here), GSK disclosed the number of violations, breaches, dismissals and warnings with respect to sales and marketing misconduct,  claiming "these numbers are very similar to those reported by other companies in our sector." Well, is that a good or bad statistic?

Nonetheless, what really caught my attention with respect to this article was the use of "free samples" as part of the "incentive scheme," as juxtaposed  to GSK's "rouge employee(s)" insinuation. While I am not an investigator, journalist nor compliance practitioner, I do have some experience when it comes to controlled samples (assuming these drugs are subject to some level of regulatory and customs control), and thus, I think there is an additional component to this issue.

From my perspective, it would be difficult, if not impossible, for a salesperson to transfer samples for re-sale, either through carrying such samples to the end user, which would require a carnet (see here for carnet information), or even by shipping them, without other individuals and departments knowing that these samples would never return to their point of origin. Furthermore, when shipping or carrying samples, there are numerous customs and regulatory declarations that the samples are either going to be returned, or that they are not subject to re-sale, or both. Thus, at minimum, we have what could be a serious disregard for customs and export declarations in this scheme. 

Again, assuming that given the business in which GSK operates, that they have strict shipping and accountability protocols, including internal and perhaps regulatory audit, that the "we didn't know" just does not square with this type of operation.  It requires too much internal and customs paperwork for such samples to simply "disappear" without  the knowledge of  support and/or management personnel.  Furthermore, one would think that Glaxo would have internal tracking protocols which would alert them when product simply "disappears." As someone who spent over a decade dealing with the issue of controlled samples and international shipments, there is, most likely, a logistical and/or managerial underbelly to this story, beyond the "its just a few." Expensive sample drugs, such as those referenced in the article,  just don't disappear without someone signing off on the expense. 

Maybe Its Part of a Greater Issue, Maybe....

One day later, as reported in Reuters (link here), GSK appeared to have broadened their reaction, given prior corruption issues in other countries, including China, declaring that they will commence to "build a new sales model designed to eliminate sharp marketing practices."  What caught my attention was the quote attributed to GSK Chief Medical Officer James Shannon when he stated  that "sometimes you have to step backwards to move forward.." and continued, "this is an entire rethink about our business practice." When I hear a C-Suite executive publicly stating that the company is looking at a total shift in the business model when it comes to their international business strategy,  I pay attention. 

Why? Because it means that management has accepted that a tinkering of the existing model, including a shifting of compliance and ethics priorities, will not suffice in addressing the issue of international corruption. Its too deep, and even if not "discovered," it remains too engrained in the operating mentality of the international sales, marketing and business development teams which operate in high-risk regions known for corruption.  Thus, it appears in this report, that GSK is no longer content with their problems being "similar to those reported in other companies."

So, What are the Alternative Models?

Coincidentally, while reading the current reporting on GSK, I had the benefit of getting a link on  the HBR Blog Network called "How GE and IBM are Playing Global Development to Win," by Jonathan Berman, as posted on April 16th, 2014 (link here). I read Mr. Berman's post, then immediately ordered his book Success in Africa: CEO Insights from a Continent on the Rise  (link here). In his post, Mr. Berman lays out what I consider to be no less than a total change in  international business modeling, whereby GE and IBM (as two examples) analyze countries not as customers but as business development partners.  It is a mutual investment of time and resources to identify the infrastructure challenges a country faces and then to examine the potential role that the corporation can play in meeting those challenges.

Mr. Berman describes compelling examples of how both GE and IBM used the "development to win" model in order to "spur economic development and create opportunities for their companies." Thus, it is not your traditional "sales cycle" approach to business development with the standard marketing SWOT analysis (strength, weaknesses, opportunities and threats); it is much deeper, as it engages the customer, and in this context we are speaking of state owned entities, as a partner,  not just a  recipient of products and/or services.  Futhermore, in my opinion, it also reduces the level of risk which impacts overseas compliance, bribery and corruption by taking a longer term and patient approach to international business development.

Long Term Vision and the Reduction of  Risk

Again, from my perspective, a longer term horizon with respect to the international sales cycle means less exposure to corruption risk. Why? In many countries and regions the sales cycle is unstable, subject to delays due to regime change, personnel turnover, funding delays and procurement instability. Much of the history of  FCPA enforcement relates to companies trying to "overcome" these instabilities. Thus, a long term vision, as stated by Mr. Berman, includes:
  • An upfront "investment of money and time to understand the growth challenges" in the perspective country.
  • "Senior management and board involvement." Adding that "companies playing development to win have CEOs traveling to the region 2-3 times per year, supported by engagement of the full management team." Accordingly, here we have the involvement of the C-Suite in the international business development process, stepping outside the normal organizational groupings of sales and marketing personnel.  
  • A vision of earnings, investments and returns which are "long term" and "its common to invest for a decade or more before shareholders see material earnings."
As Mr. Berman concludes, "The companies playing development to win need the institutions and policies with which they are engaging to yield tangible results," which in the case of infrastructure investment in state entities, means providing the benefits of those projects to the citizenry. Thus, going back to the paradigm shift, if we think of transactions involving bribery and corruption as producing short term gains, where the immediate beneficiaries are the companies receiving the contracts and those receiving the bribes, this model takes that gain out of the equation. In the "playing to win" model, the vision is long-term, whereby both the corporation and the state both have a sustainable investment in one another, and results are delivered to their mutual constituencies in order bring long term value to all.  It is a positive definition of mutual dependence and both parties have a lot to lose if they don't deliver meaningful value.

In my view, this shift takes the entire debate on corruption and compliance, both in terms of ethics and programs, to a different level of engagement. I am looking forward to reading Success in Africa, CEO Insights, from a Continent on the Rise,  for deeper understanding.

Tuesday, April 15, 2014

"Why Transformation Efforts Fail," Final Lessons.

David Stulb, Global Leader for Ernst & Young, Investigation & Dispute Services, in introducing Maryam Hussain's recent book Corporate Fraud, the Human Factor, (link here for more info) states that "aggressive prosecution of bribery and corruption is increasing the risk of operating in many new markets. Yet these are the same markets which are critical to business growth and establishing a sustainable supply chain."  I think of that potential  tension between overseas business growth and corruption when concluding my thoughts on John Kotter's work on corporate transformation, which in the context of this discussion, includes transforming a corporate culture to embrace a true anti-bribery ethic and program. As in prior posts, I continue to focus on the relationship between compensation and compliance as part of that transformation process.

John Kotter, Konosuke Matsushita Professor of Leadership, Emeritus, Harvard Business School, in “Leading Change, Why Transformation Efforts Fail,” (HBR, January 2007) discusses why companies seeking to change the way they operate in a new “more challenging market environment” often encounter internal institutional resistance from “those in the trenches of the business,” and why “leading change is both absolutely essential and difficult.” Today I will conclude my discussion of his work  as relating to my own experiences, and to bring the reader through Kotter's thinking  so that others may consider how to “avoid the common pitfalls.” For those who are interested in learning more, including the details of eight unique steps to transformation, here is a link to the work.

If transformation includes the creation and sustenance of a true anti-bribery culture and program, then incentive compensation for a sales and marketing organization needs to be aligned with desired behaviors to insure that compliance and compensation do not become a zero-sum game. As Kotter states "sometimes compensation or performance-appraisal systems make people choose between the new vision and their own self interest." Hence, as in my prior post where I reference the MIT Sloan Management Review article called "Combining Purpose with Profits"if the C-Suite is proclaiming the "pro-social" goals an anti-bribery effort while delivering a financial message as articulated through a lucrative sales compensation plan to "bring home" the financial goals of sales over compliance, then the best FCPA compliance program will be diluted, or worse, discarded by the time it reaches the overseas sales and marketing organizations.

Kotter concludes that "change sticks when it becomes "the way we do things around here," when it seeps into the bloodstream of the corporate body," and he adds that "until new behaviors are rooted in social norms and shared values, they are subject to degradation as soon as pressure for change has been removed." From my perspective, compensation needs to be a part of that "bloodstream" to insure that incentives align with desired behaviors.  While I was struggling to describe what that transformation might look like, I refer to Andrew Leigh's book Ethical Leadership, Creating and Sustaining an Ethical Business Culture,  (see here for more information) where with permission of the Ethics Resource Center, he illustrates a chart (referencing Prudential Financial, Inc.) called "making the right choices." The chart lists Four Ethical Filters for Decision Making and  I have taken the liberty to put them in a general context, as follows:

1. Policies: Is a decision consistent with policies, procedures and guidelines.

2. Legal: Is the decision legal?

3. Universal: Does the decision conform to company values? Does it benefit stakeholders, internal and external?

4. Self: Does the decision "satisfy my own personal definition of right, good and fair? Can I be proud of this decision or action?"

If a company has implemented a "transformational" anti-bribery program and ethic then individual and organizational decisions throughout the sales and marketing organizations, no matter how far from the "C-Suite" will always be "yes" to the above, and where there is uncertainty, the employee will feel secure in calling upon corporate resources "available to provide... guidance to make sound ethical decisions." I think the above four criteria provide a solid foundational definition as to  how transformation results in a "bloodstream" anti-bribery culture.

I was recently watching a video from the  2013 Dow Jones Compliance Symposium, moderated by Nick Elliott,  Editor, Risk and Compliance Journal, Wall Street Journal, (link here), where Peter Y. Solmssen, General Counsel, Siemens AG, was talking about a project manager who was working in Thailand, who stated that when he is working on a deal, his response to a corrupt event is not "compliance won't let me do that," but that "I don't do that." In my opinion, and the history of change at Siemens has been well reported, that is is what I would characterise as  true transformation.

Sunday, April 6, 2014

"How to Bribe" by Transparency International. A Review and Recommendation for Organizational Value.

I recently had an opportunity to read Transparency International’s (UK) paper “How to Bribe, A Typology of Bribe-Paying and How to Stop It,” (link here) written with the support of Pinset Masons and (January, 2014). The authors state that the purpose of the publication is to “illustrate how bribes are paid in practice, based on legal cases and realistic experiences.” They go on to describe why they took the time and effort to compile 46 pages of bribery scenarios: “to help individuals and companies anticipate, recognize, avoid and resist bribery.”  The authors, based on my experience, accomplish both goals.  First, in the description of “how bribes are paid,” they use both broad and specific examples to surface a wide and relevant variety of bribery scenarios. Second, for each group of bribery activity they have a concluding segment which includes guidance on how to “look out for red flags and fact patterns” designed to assist the reader in the early detection of bribery.   In my judgment, the authors’ call-to-action is succinctly and accurately identified in their own reference to this work as “a source book for training, avoidance and for designing adequate procedures to prevent bribery.”

I would like to call attention to a number of interesting and relevant chapters, and then make a recommendation as to exactly which groups I think would benefit from this exhaustive and impressive paper.  In one of the early chapters, I focused on a recommendation under “Know How to Deal with a Bribe,” which advocated that a company “ensure that any staff who withdraw from a business opportunity because they refuse to pay a bribe know they will have the support of their line managers and senior managers.” I have referenced this corporate maxim in my repeated discussion about how it only takes one manager or senior executive in a company to be out of message alignment, in order to distort, or worst case, discard, the entire anti-bribery culture of an organization.   Line employees need to know that they work in a culture which rewards compliant behavior, financially and otherwise, regardless of the short-term financial consequences of “walking away” from suspect transactions. 

In Section 2.1 “Bribery Through Associates: Middlemen,” the authors call attention to five variations, of which I view the second presents as presenting a great challenge to individuals and organizations which are trying to vet and screen their third parties (e.g. agents). This category is identified as “intermediaries providing both legitimate business services and a bribery service.” In this case, a third party might have good references, solid credentials, and a record of success based on legitimate services, while masking the bribery component under the smoke screen of financial achievement. From my perspective, this is a very challenging and relevant real-world issue.  An agent like this can be attractive to a company or line sales person looking for an in-country business partner, and to complicate matters, the component of the intermediaries “bribery service” in some regions, might go from one extreme to another depending on regime change. Thus, the snapshot of an investigation or vetting process might find that entity as “legitimate” at one point in time, and then after a regime change, where the agent now has "connections in place," the opposite might be true. I would be interested to hear from compliance and investigatory professionals as to how they account for this type of scenario.

Speaking of third parties, in the same chapter under “guidance,” the authors talk about the importance of communicating “to all agents and intermediaries the company’s anti-corruption standards as well as international regulations and ensure that they are contractually obliged to abide by these standards.” I think that this is invaluable, but often ignored advice.  The communication of anti-bribery ethics and programs, even at the introductory state of a third party relationship, makes the message loud and clear: either you are on “our program,” or find another partner.  In my opinion, this is critical preventative messaging which can help companies avoid great financial and reputational damage later on in the relationship.

These are but a few examples, where I call attention to the value of the work in both detailing the diversity of bribery activities, while offering valuable recommendations to help with early detection. So, when I had completed reading the paper, I asked who would benefit from this work?  I came up with two distinct, yet dramatically different groups:

1. Small to Medium sized businesses looking to grow overseas. In a recent K&L Gates paper entitled “DOJ and SEC Representatives Tackle Pressing Anti-Corruption Issues in 2014,” (link here) there was a discussion of how the DOJ and SEC recognized that “small companies may have little money to build state-of-the-art compliance programs, but that these companies still need to find ways to manage their corruption risk profiles.”  For such a company, new to the international marketplace, this work is a great starting point for understanding the potential scenarios, risks, and possible methods of detection which can operate in overseas sales. While such a company might still need to bring in external compliance support, or to increase their internal “bench strength” to shore up an anti-bribery program, it all starts with an understanding of “what’s out there.” This work, which describes real-world and easy to understand examples,  all of which can shape a corrupt transaction, is of significant value to a novice individual or corporation looking to expand internationally. 

2. On the opposite end of the corporate spectrum, I would recommend this as “required reading” to any Board of Directors who sit with companies that have to manage international risk.  I specifically recommend it to the Board Members who do not sit on the audit, governance or risk committees of the Board. Why?  It will give these Board members insights and possible challenges to raise to Board members who do sit on those committees, spurring  “what about this”, “and how do we deal with that” type of questioning - of which there is a 46 page menu from which to choose! Again, for a Board member with limited international exposure and experience, this paper will provide information and examples to draw from in order to challenge those charged with governance, and to engage the full board and management on a critical discussion, as to how the company is coping with bribery and corruption risk in its compliance programs. 

I hope that this review provides some insight, based on my own perspective, as to how this work can be best utilized in the field. While I have linked the paper in my introduction, TI has graciously requested a 25GBP contribution in order to support future writings and I was more than happy to comply.

Tuesday, April 1, 2014

"Former Cisco Execs Allege Vast Kickback Scheme in Russia." The Red-Flags You Don't See.

In yesterday's Buzz Feed World, Adam Roston, Buzz Feed Staff, posted an article (link here) about allegations of bribery involving Cisco employees in Russia.  I believe this a must read for the FCPA compliance community, as the reporting details significant events surrounding foreign bribery.  Furthermore, it has a number of significant lessons for the compliance professional which I will try to frame  in the context of my own experience.

First, it shows how the consequences of foreign bribery are not symmetrical to sales volume. According to the article, Cisco sales in Russia, where the conduct occurred, "make up less then 2%" of Cicso's revenue. Against those sales  will come the consequences of the conduct, including legal and investigatory costs, business costs to unwind its in-country obligations, not to mention whatever fines (both individual and corporate) might be assessed. Of course, there is the cost of liberty, of which I am familiar, that some of these executives might face. Again, it is another example of how a small business segment gone wrong, can have a disproportional corporate cost  in terms of  dollars, reputation damage and perhaps, loss of liberty. 

There is a great deal in this article to demonstrate the obvious importance of compliance professionals who are on the constant watch for red-flags, such as after-sale rebates, designation of payments to tax-haven countries, not to mention the risk of doing business in a country with a "low integrity" reputation, all of which were present in this article. However, those are not the most troubling parts from my perspective.

"The Ostrich Defense Does Not Work."- Former DoJ Official. 

What should be highly concerning to the compliance professional is the part of the article when one of the former Cisco executives stated that when the time came to talk about the issues of where the money was going "I left the room," and when invited to remain, he said "I don't want to...."  If you refer back to my blog post "In Walks a Public Official" , this is exactly the type of behavior where  compliance professionals need to be concerned.  I ask: how many of your overseas sales personnel are "walking out of rooms," "pretending they didn't hear" or telling their agents to "stop talking" as they conduct business with third parties? You might think that it does not happen in your organization; that your sales team would instead immediately disclose the conduct to appropriate personnel and cease and desist with respect to the transaction. Right?

However, what if it is happening in the field and it is not being reported up? Perhaps now the challenge is to try to better understand how your compliance programs and corporate ethics are being  communicated down to the lowest levels of your overseas sales organization. Are your making a focused effort a to understand their challenges, and provide them with  compliance solutions that are both global and regional to help them manage and report risk in their territories?

How can I help my sales team?

You can start by taking a  walk over to the  HR Department and reviewing the compensation packages on all your overseas personnel working in "low integrity" regions to see how they are being compensated. Are people working in regions with a reputation for  corruption while having a majority of their compensation based on personal sales performance? If they are, you are building in an inherent conflict between compensation and compliance, whereby you are in fact incentivizing people to be an "ostrich."  Cicso is not unique, and I am obviously not judging this case, but what Mr. Roston described is a compliance professional's worse nightmare: Personnel in isolated, corrupt regions, looking the other way.  It is the red flag you don't see.

Again, I know its easy to say "not here," but in my experience, a major start to supporting an overseas sales and marketing team is with a compensation package that reflects the programs and ethics of an anti-bribery culture. A sales person in Germany, a highly developed mature market with a high integrity reputation should not be compensated on the same incentive plan as someone responsible for sales in  a region which has an undeveloped procurement process and ranks poorly on the corruption index.

In sum, if there is high level of individual financial upside in your sales  incentive plan along with a "low integrity" country index in that person's territory, the best compliance and ethics programs may in fact contain the "seeds to their own destruction" (a term used by George Kennan in his famous "X" article, "The Sources of Soviet Foreign Conduct." It seemed to me an appropriate quote given the territory). I know that the story of compliance and international sales does not end with a discussion of compensation, but based on my own experiences and observations its a good place start.