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 www.richardbistrong.com

Compliance Challenges


In order to ascertain if the reality of compliance in the field is aligning with the policy messages and policies from corporate executives, those who have compliance and sales responsibility should ask:

  • Does compliance have to mean “business prevention” (a term I have heard used by international sales leaders) to a sales organization? Is HR, Legal, Sales, Risk and Finance all speaking the same message to those in the field, or are those messages coming from organizational “silos” and hence, confusing at the field level? 
  • Is compliance and compensation properly aligned so that those in the sales and marketing organizations, particularly those operating overseas, clearly understand that compensation matches desired behaviors through a well articulated system of rewards and consequences? 
  • Is anyone thinking about how sales personnel in the field are being trained according to local laws and customs to reduce the potential of a “carbon copy”prosecution across countries? 
  • Is the sales force being properly trained and drilled in real-world red-flags, hazards and early warnings when it comes to bribery activity, actual or potential. What training is the sales and marketing force given when it comes to the governance of contacts and contracts with third party intermediaries? What is the sales person and manager trained to do if a bribe is discovered after the transaction? 
  • How can a corporation insure that a line sales person and/or sales manager be highly successful and rewarded both individually and corporately while embracing an anti-bribery consciousness and ethic?