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  • Richard Bistrong

One Anti-Corruption Compliance Panel: Multiple Perspectives

On July 23rd, 2015 at the Hotel Kitano in New York City, The Network ( hosted an Anti-Corruption Compliance Panel discussion titled “Why Anti-Bribery Programs Fail and How Compliance Must Evolve.” Cindy Curtin Knezevich, Vice President of Marketing Operations at The Network, along with Meagan M. Flores, Sr. Manager, Marketing Programs & Demand Generation, developed the afternoon discussion program, which was well attended by Compliance, Audit and Investigatory professionals from throughout the New York Metropolitan Area. The panel was moderated by Jimmy Lin, Growth and Product Strategist for the Network, and I was joined by co-panelist Robert “Bob” Appleton, Partner, Day Pitney. As shared in a prior blog, Bob was the former UN Procurement Task Force Chairman, who in 2006 targeted me in as part of a contract investigation, stemming from his work on the Volker (Oil for Food) Committee.

When I asked Cindy about her thought process in launching the event, given the time and expense involved in organizing the logistics, including a rooftop reception afterwards, she responded “We hosted the event because, quite simply, we could not resist the opportunity to put you and Bob, with your fascinating stories, in the same room!  We thought ethics and compliance professionals were bound to be as enticed by it as we were.”

Cindy continued “The Network believes ethics and compliance isn’t a ‘function,’ but is about all employees, so we think about engagement; when we build solutions like our Agile Code of Conduct or our Integrated GRC Suite, we build them from the perspective of ‘how can we engage employees, and how can we help them retain and apply information,’ not just from the perspective of the system administrator.  I encourage our marketing team to think about engaging our prospects and clients so we try to find topics that bring real value, and aren’t the same old papers and webinars that compliance professionals could get anywhere.

“From our first conversation, Richard, I have believed that compliance professionals could learn a lot from your experience and use your lessons to improve their own programs.  And Bob’s investigatory and FCPA background is so impressive, that even the most seasoned Chief Compliance Officer can learn something from him. Ultimately, I felt that this would provide real value to our market and do it in a way that was authentic to The Network, so truly, it was a pleasure to host.”

Paige Pulaski, Marketing Programs Coordinator at The Network, and author of a three part series on “Compliance Lessons Learned Behind Bars” (link here) commented afterwards “The story that you and Bob shared on the 23rd had our guests totally enraptured. One attendee commented, ‘It’s one thing to read about a story like this, but it’s really something else to hear both sides of the anti-corruption story from people who have lived it.’”

But the big surprise came from the following, where Paige shared “ a conversation with our videographer at the end of the event, when she mentioned it was a surreal assignment for her; she and her husband had left the country they’d considered home because of the insurmountable corruption, and there she had stood for hours behind her camera, listening to every word you two had to say about awareness of the ethical issues of bribery and how to be proactive about eliminating corruption.”

Paige reflected that “It was an eye-opening moment for me to realize that, on the extreme side of ‘no one’s getting hurt here,’ that there are people’s lives who are being completely altered to the point of abandoning their home country to the ruins of corruption. Richard, you and Bob are impacting the movement to combat this from happening by providing psychological and corporate tools to prevent unethical persuasion.”

That was an unexpected viewpoint and I hope we can invite the videographer to guest blog here sometime about her experience. I also asked Cindy if she heard from any of the attendees, to which she replied “During the cocktail hour, I spoke with someone from one of New York’s government functions.  He said this was one of the best events he had attended in the compliance space because it was unlike all the others where the content centers on ‘some regulator waving his finger at you’ and droning on about enforcement.  Richard, your perspective really resonated with him; I’m paraphrasing but he said compliance teams could really learn a lot from someone who has actually been through it and suffered the personal and professional consequences.”

We were also fortunate to hear directly from a few attendees including Kimberley Allan, CMO, ProGRCive, who shared that the event was “‪an incredibly compelling and engaging narrative. A very human tale of the psychology behind a bribe, juxtaposed against the efforts of the international regulatory community to address bribery and corruption in business. It provided practical insight into how companies serious about ethical behavior can spot red-flags, but also set up common-sense frameworks (such as how sales, particularly in high risk territories, are targeted and rewarded) to prevent it.”

Jo Sherman, CEO EDT, who has previously shared her experiences at Compliance Events (Oslo Anti-Corruption) on this blog (link here), reflected, “It’s not often that I attend a half day seminar in New York where there is standing room only.   But that was the case on the 23rd when I arrived at the Kitano to hear you and Bob talk about anti-bribery compliance. In fact, The Network advised me afterwards that there were so many registration requests that they could have filled the room many times over.

“So, why was it so compelling?   On the topic of bribery and corruption, you and Bob are so refreshingly unique because you keep it real. You are not a couple of ‘holier than thou’ compliance consultants with limited real world experience speaking about ethical best practices or preaching via bland PowerPoint’s about the world of anti-bribery and corruption.

“Its your story Richard, and it’s Bob’s story. Your real world stories from the trenches.”

When I asked Jo why someone in electronic discovery services would even register, she replied “I attended the event because we have recently realized that our software, which was actually developed for the eDiscovery and litigation markets, inherently delivers functionality that is also useful for internal corporate investigations into potential bribery or corruption.  To that end, the event provided me with practical insights into the challenges our clients face when managing projects in this domain.”

Well, having heard from the organizers and attendees, I thought I would leave my final question to my co-panelist and interlocutor over two continents, Bob Appleton, having engaged at the Oslo Anti-Corruption Conference, for his thoughts, to which he replied, “Richard, it was my honor and pleasure to participate in such a well-organized event handled so professionally by The Network, and to have the opportunity to tell, for the first time after 10 years, the rather unique story of how our paths intersected when I was an investigator and you, the subject, at the United Nations in 2006-7. I really appreciated the opportunity to share our other real life experiences confronting corruption throughout the world in the field in the following nine (plus) years before we finally met in person earlier this year.  Not unlike the circumstances that existed when our paths crossed in 2006, corruption remains a very real problem for, and challenge facing, any corporation seeking to do business abroad – as well as any company, foreign, domestic or multi-national, worrying whether the FCPA can and will reach them.”

Bob added, “I hope that the information imparted from our years of experience in the field was not only entertaining, but of value to the attendees in meeting the very real and significant corruption challenges that continue to be present today.  My profound thanks to you Richard, for approaching these issues so genuinely and thoughtfully.”

My only postscript would be one of thanks. First, thanks to The Network for reaching out to me after my first months of blogging in early 2014, with a call from Cindy saying “we want to know more” and commissioning the Behind the Bribe white paper (link here for download). Cindy and her team were one of the few, back when I started, that provided the encouragement and ‘fuel’ to continue my outreach and trajectory. There are always people that you think of in your career as providing unconditional inspiration, well, The Network was/is that for me. And continued thanks to Bob Appleton for responding to my “remember me” e-mail after I read his interview with Sam Rubenfeld in the WSJ (link here). We have been reminiscing ever since, but not simply the exchange of war stories; rather, we are constantly challenging ourselves and our communities to consider “what does this all mean to today’s compliance challenges.”

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