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Richard Bistrong: My UN bribery prosecution had a different beginning

When a TV news anchor asked me the difference between the alleged bribery scheme involving former U.N. General Assembly President John Ashe and my own, where I was charged with conspiring to bribe a UN official from 2001 until 2006, I said that from an investigatory perspective, they were opposites.

In 2006 I received a fax from the chair of the UN Procurement Task Force (PTF), Robert Appleton, asking about a contract, a third party, and me. I knew where he was headed, and I ignored him and his fax.

A few months later, a determined Mr. Appleton tracked me down in the UK, where he sent me the same fax. What I didn't realize was that by then Mr. Appleton was in contact with my employer and was also sharing his findings with the United States Justice Department.

Shortly after the second fax came, my employer fired me. Then my real troubles began. I ultimately pleaded guilty to the UN conspiracy (among other FCPA violations) and served more than a year in a federal prison.

My case wasn't unique. On other PTF-driven investigations where there was a handoff from the UN to the DOJ, UN employees and contractors ended up serving prison sentences and the UN debarred over 45 outside contractors.

In 2009, the UN Procurement Task Force’s funding expired and wasn't renewed. Since then, we haven't heard much about corruption in the UN, until this week.

U.S. Attorney Preet Bharara said at his press conference that “we will be asking: Is bribery business as usual at the UN?” And a spokesperson from the UN said “we just learned of the very serious allegations this morning.”

And therein are the opposites between my prosecution and this week's news. The new charges were the result of a focused FBI investigation with the UN as a bystander. In my case, an investigation started within the UN and was then shared with the DOJ.

In any organization, results are driven by focus and commitment, as the UN's pursuit of me and others demonstrated. Given the Procurement Task Force's record of success  -- and I have the prison card to prove it -- we should be asking why the PTF's funding expired, and why the UN became a bystander to perhaps the biggest corruption investigation in its own history.


Richard Bistrong is a Contributing Editor of the FCPA Blog and the CEO of Front-Line Anti-Bribery LLC. He consults, writes and speaks about compliance issues. He can be reached via his website, twitter and email.