In the Vulnerability to Resilience series, we have explored how small and medium enterprises (SMEs) use their vulnerabilities to create. SMEs possess the agility that enables them to identify risks early and maintain community and business relationships, which SMES can leverage to prioritize integrity and open new markets. Cooperation allows SMEs to raise their ethical standards in the market. In this next segment, we examine another SME advantage: the power to innovate.

For small and medium enterprises (SMEs), compliance feels like a lonely climb up a steep mountain. Costs are high, rules are constantly evolving, and there is pressure to cut corners to keep pace. Standing alone, an ethical SME can lose when competing with actors who ignore the rules.

With the halt to the FCPA earlier this year, a lot of compliance teams reached out with questions on what compliance topics remain relevant and top-of-mind with shifting policies.    The shift in enforcement announced by the DOJ in June and the latest declination for FCPA violations announced in August conveyed that there are tried and true compliance topics that should continue to be enforced each and every year, throughout the year. And these should always be top-of-mind.

Several months ago on this blog, I examined the role that impact investors can play in advancing the fight against corruption in conversation with Ambassador John Simon of Total Impact Capital. To explore this important question in further detail, I spoke recently with Huma Yusuf, Director, Business Integrity, and Varun Sharma of British International Investment (BII) and Chara de Lacey, Head of Business Integrity at Transparency International UK (TI-UK).

In Part One of this series, we explored how the investigation into Representative Alexandria Ocasio-Cortez’s appearance at the 2021 Met Gala unfolded, and what it revealed about the burdens, inconsistencies, and reputational risks of regulatory reviews. While the ultimate outcome was limited to additional payments, the years-long process underscored the steep costs of even minor compliance missteps.

Last month, the bipartisan House Ethics Committee wrapped up a long-running investigation into to Representative Alexandria Ocasio-Cortez’s appearance at the Met Gala in September, 2021, concluding that she did not pay enough for a custom-made dress she rented for the event – thereby making it a prohibited gift...