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  • Richard Bistrong

A Summer of Compliance

When I was working in the field of international sales, August was typically a month of ‘down time’ as a combination of end user, third party and corporate holidays marked a lull in summer sales activity. Well, I have not experienced such a drop-off in the world of anti-bribery compliance, where it seems to be that ‘compliance never sleeps.’ But as I look at the remainder of 2015,  I have been thinking of some social media advice given to me early on by Deirdre Breakenridge, author, “Putting the Public Back in Public Relations: How Social Media Is Reinventing the Aging Business of PR,” (link here) and that advice was “be a giver.”

The challenge has been to somehow distill and share the deep and wide level of content that pertains to anti-bribery compliance, especially where I look to areas of focus outside the mainstream news feeds of enforcement actions, investigations, and trends. Rather, what has interested me are issues pertaining to behaviors, decision making, individual enforcement, as well as to the continued environment of corruption which exists in the field. Thus, I am greatly indebted to those who have elevated such topics and continue to do so in their writing and speaking. I don’t mention them by name as for certain, I will regrettably, and via an error of omission, forget someone who has provided significant thought leadership. However, with that preamble, I still must thank Philippe Montigny, Scott Killingsworth, Alison Taylor,  and Dr. Roger Miles, who not only shared great thought leadership and content, but who also provided me with significant encouragement so early in my writing efforts.

As to how to best capture such leadership, research, and content, I have turned to a really engaging service called Trap.It, which through a sophisticated content analysis platform, is helping to bring this information to ‘my front door,’ in a way is really well organized and resonating. As their website says, “Surface original, high-quality content you won’t find elsewhere” and that’s exactly what they do. The service has really supported my efforts to find relevant, engaging and hard to find content on the ever-expanding web, and their intuitive platform has been a major part of helping me to discover content that I never knew existed.

As to how I then share that content, I have recently, through an association with Rightside, secured the domain, as part of their product launch of the custom domain .NEWS. (FYI, the design is not yet completed, so the link simply redirects to Why .NEWS? As Marc Gawith, Business Development Manager, Rightside,  shared, “the new .NEWS domain was launched for the old media and the new. From major outlets publishing in-depth investigations to grassroots initiatives spreading the word through social media, the business of reporting will gravitate to .NEWS to find out what’s happening, right now in the moment.” In addition, with respect to the use of custom domains, Marc added,  “up until now most companies had to  settle for long, possibly hyphenated, .com domain names, as availability continues to contract.  Now with new domain extensions like  .NEWS, and .ATTORNEY, professionals have a domain extension that is specific to their industry.  These domains are more memorable to the right of the dot with more availability to the left of the dot.  Richard, Google just paid $25 million for exclusive rights to  “.app” so this is a trend which continues to rise.”

Thus, through a combination of Trap.It and, I hope to spend more time elevating the work of new thought leaders and researchers, who might fall out of the traditional ‘compliance zone’ in order to advance how such work has relevance to the field of anti-bribery compliance.

For example, I recently read Dorie Clark’s book, Stand Out (link here) after having read her work Reinventing You while I was in Prison. Thanks to the team at JD Supra, I had a chance to share Dorie’s work with the JD Supra legal and compliance community in a piece called “Online Reputation Management: How Your “Bad and Ugly” Translates Into “Good” for Others.” (link here). Another work I intend to share in the near future is The Looting Machine: Warlords, Oligarchs, Corporations, Smugglers, and the Theft of Africa’s Wealth by Tom Burgis (link here), which is a compelling book that brings the front-line of corruption in the oil and gas field to the general public. It is a work, when combined with Sarah Chayes Thieves of State, which should be required reading for those in the field who might think of bribery and corruption as a victimless crime.

Back to being a ‘giver,’ and a few more compliance shout outs.

My deep appreciation to the team at The Network, who have taken my intersection with Robert Appleton in 2007 when he was Chief of the UN Procurement Task Force (PTF), and elevated that investigation as the centerpiece for an anti-bribery panel in NY, where another one is now scheduled for Boston on September 17th (registration link here). They have been a pleasure to work with, starting from our Behind the Bribe White paper (link here), which led to a webinar and now the live multi-city panels. Another moment of gratitude goes to Dick Cassin and his team at the FCPA Blog. I have been following the FCPA Blog for quite some time and the opportunity to be a part of the Blog’s community has really a major ‘best of’ in 2015.

As to the remainder of the year, I am really looking forward to contributing a chapter to the 2016 edition of Trace International’s How to Pay A Bribe, as well as to a number of pieces on The FCPA Report. I am also working with Nicole Rose, CEO, The Centre of Excellence and Create Training, where she has invited me to be a part of a major training initiative, which is soon to be announced. I also want to thank Alain Pirot, an incredibly talented videographer, for producing this video called “From Behind the Bribe” (link here) and again to Dick Cassin, as well as to Maurice Gilbert and the team at Corporate Compliance Insights, for sharing it with their communities.

I am also looking forward to a number of programs, via live presentations, webcasts and whitepapers with ethiXbase ( Given my own background as a corporate executive who bribed, cooperated with international law enforcement, and who served prison time for my own offenses, there is a natural synergy with ethiXbase, who helps their clients to shield themselves from bribery and corruption in their own third party networks. “It is important for compliance practitioners, in-house counsel and senior management to understand practically how bribery and corruption can occur in real life situations” said Leas Bachatene, Chief Executive Officer, ethiXbase. “Richard, for this reason we are pleased to partner with you to educate compliance professionals about ways in which they can shield their business from bribery and corruption by third parties and sales agents who operate on the front lines.”

Speaking this fall also looks quite robust and I have started an events page (link here). So, while I might have bitten off a ‘little more blogging and speaking than I can chew,’ I am really looking forward to this second half of 2015. While my discipline of posting a new blog piece every Monday morning might slow down as to keep my commitments to the aforementioned organizations, I hope to be back on my weekly schedule by late September. However, once I get Trap.It and ‘talking to one another,’ I will be posting the work of other thought leaders more often.

Less than twenty months ago I was on the bottom bunk of a two man cube at the Federal Prison Camp at Lewisburg PA, and thus, this seems like an appropriate time to pause and be a ‘giver’ by thanking all of those who have supported my journey, and continue to do so, since I stepped out of the Camp and into my car on December 17th 2013.

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