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

Media

  • Chris Matthews, Reporter, Wall Street Journal, has reported on a number of FCPA cases (including my own) since 2009. Here is his article "How a Former Executive Went Undercover for Prosecutors," published on March 24, 2014, where he discusses the use of "investigatory tactics" in past and future white collar criminal investigations.
  • Joel Schectman, reporter for the Wall Street Journal, Risk & Compliance Journal, in the article, "Former FCPA Chief on DOJ's Tough Tactics", published on March 25, 2014, interviews Chuck Duross, now partner at Morrison & Foerster LLP. Mr. Duross, while at the Department  of Justice, led the FCPA unit. In the Q and A, Mr. Duross shares his reflections about his own "stamp" on FCPA enforcement.
    • On April 23, 2014, I was interviewed by Chris Matthews, Wall Street Journal Reporter, at the Dow Jones Global Compliance Symposium, in a session called "Informing on Bribery." Here is a post where Joel  summarizes much of what was discussed during the Q and A. 
  • Samuel Rubenfeld reports regularly on FCPA issues on Corruption Currents, Risk and Compliance Journal, Wall Street Journal @WSJRisk. 
    • Here is a reference (July 15, 2014) on my review of How to Pay a Bribe (2014, edited by Alexandra Wrage, Seven Wirz) and the chapter on bribery in Latin America by  Matteson Ellis.
    • Here is a mention (July 22, 2014) on my thoughts about an article by Scott Killingsworth (Partner, Bryan Cave) and the extension of C-Suite ethical concerns to the front lines of international business. 
    • Here is a mention (July 29, 2014) of my piece on the Kroll and Compliance Week "2014 Anti-Bribery and Corruption Benchmarking Report," where I discuss some of my experience with third party intermediaries and the impact of regime change,
    • Here is an article (July 30, 2014) on my reflections with respect to  remarks given by Thomas C. Baxter, NY Fed concerning "The New Compliance Landscape." I specifically discuss the issue of FCPA "facilitating payments" in the context of business thinking at the front lines of international business.

  • Mike Koehler, the owner and moderator of The FCPA Professor, engaged in an extensive Q and A with me on April 14, 2014. The post on our Q and A appears here. The full Q and A, which can be downloaded as a PDF,  is available here.
  • Andrew Leigh,  author Ethical Leadership, invited me to guest post on his blog Making Sense of Ethical Leadership.  Accordingly, I shared my thoughts about the challenges of compensation incentives in the context of an anti-bribery corporate policy and ethic. Titled "How Incentives Can Distort Sales Honesty, I once again called attention to the potential distortion of the compliance message when it is not aligned with individual and corporate financial incentives.
  • Professor Mak Yuen Teen (Associate Professor of Accounting at the NUS Business School) discusses the issue of plausible deniability in how corporate executives deal with bribery enforcement and the involvement of corporate personnel. In his posting, which was an article in the Singapore Business Times (May 21, 2014), then posted on his blog Governance for Stakeholders (May 25, 2014), Professor Mak references the reporting with respect to GSK and my own writing about how "Corruption has no witness." I recommend this article as a "must read" for those interested in how how the C-Suite often hides behind "business conduct codes" in order to have a "plausible deniability" defense while "looking the other way" as to how business is conducted within their own organizations in highly corrupt regions.
  • Thoughts on  Corporate Governance and Responsibility Blog.  Here  is my guest post on Bribery, Business Strategy and Plausible Deniability from May 29th, 2014.
  • Ethical Boardroom.  Here  is my editorial from June 12th, 2014 "A Solid Business Strategy as the Foundation of Anti-Bribery Compliance." This work was also referenced (here) on June 17th, 2014, on  Corruption Currents, Risk and Compliance Journal, Wall Street Journal, Sam Rubenfeld reporting.
  • Ethic Intelligence.  Here is my Q and A on Experts Corner on "What Happens When Business Strategy Becomes A Red-Flag for Bribery."