In 2016, I took the nickname “the evangelist of conformity”. I did this because since 2010 I have been writing on the nuts and bolts anti-corruption and anti-corruption compliance programs. In 2011, Howard Sklar introduced me to the world of podcasting when he asked me to join him on the original version of This week at the FCPA. This led me to start my own podcast, The FCPA Compliance Report, and later founding the only podcast network, the Compliance Podcast Network. In short, I have used social media as a platform to talk about many aspects of anti-corruption compliance, the practice of compliance, and provide solid information for the compliance practitioner.
I took the nickname and continued to evangelize (in ancient Greek – bearer of good news) because compliance is how I can help fight the global scourge of corruption. The United Nations (UN) estimates that more than $ 3 trillion is lost each year due to the global scourge of bribery and corruption. Every day, in everything I do to bring the good news of compliance, I feel like I’m helping fight the good fight in a little way.
I often quote the story of former Secretary of Defense Robert Gates, who wrote in his memoir, titled “Homework: Memoirs of a Secretary of War“,” During a private meeting, the king [King Abdullah of Saudi Arabia] committed to a $ 60 billion weapons deal including the purchase of eighty-four F-15s, upgrading seventy-15s already in the Saudi Air Force, twenty-four Apache helicopters and seventy-two Blackhawk helicopters. His ministers and generals had strongly urged him to buy Russian or French fighters, but I think he suspected it was because some of the money would end up in their pockets. He wanted all Saudi money to be used for military equipment, not in Swiss bank accounts, and therefore he wanted to buy from us. The King explicitly told me that this huge purchase was an investment in a long-term strategic relationship with the United States, binding our armies for decades to come.
I would ask you to consider how many US interests can be identified in the above quote? I can identify at least five: (1) US security interests; (2) US foreign policy interests; (3) US military interests; (4) American economic interests; and (5) US legal interests as reflected in compliance with the Foreign Corrupt Practices Act (FCPA). For any person or business that doesn’t think the FCPA has a positive side, I recommend the Gates quote, buried on page 395 of a 618-page book, that didn’t even deserve an Index entry. Yet I find this to be one of the finest, clearest, and most concise claims of the positive power of anti-corruption compliance. Anytime you face criticism of your compliance program, a senior executive wants to know why you need resources to comply with the FCPA, or hear a coworker complaining about how “these people” are. do business in a corrupt way, I suggest you read this quote to them. to show the power of compliance in international business.
Everyone has a role to play in tackling the scourge of bribery and corruption. Certainly, regulators have a role to play in law enforcement, just as others have a role in commenting and criticizing these regulators, at least in a democratic society. Yet, because there is a commercial solution to this problem, there will be companies that will provide these commercial solutions. This is how a market economy works in a free society; there is a business need and the market is moving to fill that need. In the case of anti-corruption compliance, this need can range from legal services to technology solutions.
But now we have a new story and a new reason to fight bribery and corruption. Last week, President Biden announced, âCorruption is a risk to our national security, and we must recognize it as such. Today, I am publishing a National Security Anti-Corruption Study Memorandum to establish anti-corruption as a core US national security interest. With this memorandum, I call on departments and agencies to make recommendations that will significantly strengthen the ability of the US government to fight corruption.
This means that we can all join not only in the fight against the international scourge of bribery and corruption, but that we can now participate directly in the fight against risks to national security. Gates’ story demonstrates the power of a commercial solution to the legal problem of corruption. But now that role has expanded to a matter of national security. So, I will expand the role I evangelize on, the commercial solution to the legal problem of corruption around the world, to include the national security interests of the United States. I will evangelize through commentary, news, and compliance know-how. I will continue to use the ever expanding world of social media to further this evangelism of conformity.
But you can join me in this evangelism. Anyone who posts or retweets a compliance Tweet, writes a compliance post on LinkedIn, or shares someone else’s post is evangelizing compliance. As important as I thought compliance was before President Biden’s statement, because of the direct link between corruptionï crimeï terrorism; the president’s statement has now made that link a national security issue for the United States. I hope you will participate in this evangelization with me. One person can move the ball a little bit each day, but collectively we can all move the needle forward by talking, writing, blogging, tweeting (and using all other forms of communication) to bring the good news. of compliance. I hope you will join me in this crusade. Anyone can be a conformity evangelist.