

Vulnerability to Resilience (Part 2) Building the SME - MNC Compliance Relationship
Leveraging SMES compliance and integrity advantages is both strategic and necessary for MNCs. MNCs have large and uniform integrity programs that drive compliance. However, Home Office compliance teams may be slower to respond to emerging risks. SMEs can help MNCs improve their knowledge and response time to emerging risks as they have agility, a local perspective, and can serve as an early warning system for MNC integrity systems...

Michele Crymes
Aug 28, 20252 min read


From Vulnerability to Resilience (Part 1) The SMEs Compliance Advantage
The compliance field often positions small and medium enterprises (SMEs) as too small for compliance. MNCs may view SMEs as high risk and the weakest link in a compliance program. This series will challenge that perspective by building off discussions on how SMEs can build imperfect integrity programs and thrive while building integrity into their operations with fewer resources. And will take an in-depth look at how SMEs engage in effective compliance and build meaningful in

Michele Crymes
Aug 26, 20252 min read


Can Private Sector Anti-Corruption Collective Action Find Renewed Importance?
Strong corporate governance, business ethics and robust compliance, underpinned by clear laws and effective enforcement, are critical to combat corruption. However, in its seminal 2008 Fighting Corruption through Collective Action: A Guide for Business, the World Bank Institute documented “a third area”: tools “that allow companies to come together collectively and voluntarily to raise practice standards and to reduce corruption,” including “integrity pacts…

Marc Schleifer
Aug 21, 20253 min read


The Liberty Mutual Declination: The Same, Only Different?
Earlier this month, the U.S. Department of Justice agreed not to prosecute Liberty Mutual Insurance Company despite evidence that its subsidiary paid nearly $1.5 million in bribes to officers of six state-owned banks in India. As part of the declination agreement, Liberty Mutual enhanced its compliance program, and agreed to disgorge profits.

Dave Lee
Aug 19, 20254 min read


Shifting Goals, Steady Focus: Staying Aligned Amid Change
Thankfully, technology can help with many of these pivots in compliance plans—keeping you on track and efficient—allowing time to still focus on pressing compliance concerns throughout the year.

Blaise Stanicic
Aug 14, 20252 min read


The FCPA Files: Owl Securities and Investments (2001)
Stephen Kingsley had a way of coming up with big and implausible plans. An Englishman living in Kansas City, reportedly experienced in the arts of marine salvage and port development, he masterminded a proposal for a massive revival of the Port of Limon on the Atlantic shore of Costa Rica, which had suffered severe damage in a 1991 earthquake. He established a group of on- and offshore companies under the name Owl Securities and Investments. The project’s aim, as pitched to w

BriberyMatters
Aug 12, 20252 min read
