Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

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Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

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Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

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Whoa! Enforcement and compliance are breaking out all over

We've talked this week about the spread of anti-corruption enforcement outside the United States. First we sampled corporate actions, and then prosecutions against individuals.

Here's more evidence of an upswing in both enforcement and compliance around the globe.

Let's start with the International Anti-Corruption Academy (IACA). It was established in Vienna a few years ago. The founders were the United Nations Office on Drugs and Crime, the European Anti-Fraud Office, the country of Austria, and other stakeholders. It now has 62 member parties.

The IACA specializes in training mid-career anti-corruption professionals, including prosecutors and regulators from around the world, with an emphasis on developing economies. It runs short and mid-length training courses and programs. In 2012 it launched a two-year Master in Anti-Corruption Studies (MACS).

The first MACS graduating class receiving Masters degrees last year consisted of 22 students from 12 countries -- Nigeria, India, Uganda, Romania, Portugal, Zambia, Liberia, Austria, Afghanistan, Azerbaijan, Canada, and Ethiopia.

The current MACS class (2014 - 2016) includes 30 working professionals from Afghanistan, Angola, Austria, Australia, Azerbaijan, Bahrain, Brazil, El Salvador, Germany, India, Italy, Liberia, Malaysia, Netherlands, Nigeria, Serbia, Sierra Leone, South Sudan, Switzerland, Tanzania, Thailand, and Uganda.

*    *     *

The Society of Corporate Compliance and Ethics (SCCE) is a non-profit member-based association for compliance professionals. The SCCE started in 2004 and is headquartered in Minneapolis, Minnesota. The group, headed by CEO Roy Snell, offers training, certification, networking, and other resources to more than 4,800 members.

More than 1,650 SCCE members hold the group's Corporate Compliance & Ethics Professional (CCEP) certification.

The SCCE is growing, both inside and outside the United States. This year the group is running its well-known Basic Compliance & Ethics Academies leading to a professional certification around the U.S. and also in London, Brussels, Sydney, Singapore, Sao Paulo, and Dubai.

Outside the U.S., the SCCE now has close to 700 members in 70 countries. Of those non-U.S. members, 485 are holders of the Certified Compliance & Ethics Professional-International (CCEP-I) designation.

*     *     *

Three years ago, more than 75 percent of the FCPA Blog's readers were in the United States. Today just over half of our 90,000 unique monthly readers are in the U.S. The rest visit from more than 170 other countries.

Last year, 30 authors from outside the U.S. contributed posts to the FCPA Blog. They were in New Zealand, the Philippines, Hungary, Canada, Singapore, France, Switzerland, Germany, China, Russia, the UK, Australia, the Netherlands, India, and Peru.

Those 30 authors from outside the U.S. contributed about 100 posts during the year.

*     *     *

Issuers (as the FCPA defines them) are noticing more global enforcement and letting shareholders know the risks.

Here's part of an FCPA risk disclosure from Eli Lilly's Form 10-K (Annual Report) filed with the SEC last week:

In addition to the U.S. application and enforcement of the FCPA, the various jurisdictions in which we operate and supply our products have laws and regulations aimed at preventing and penalizing corrupt and anticompetitive behavior. In recent years, several jurisdictions, including China, Brazil, and the United Kingdom, have enhanced their laws and regulations in this area, increased their enforcement activities, and/or increased the level of cross-border coordination and information sharing.

*      *     *

What's it all mean? For those who pay bribes, or don't do enough to prevent them, the world is getting smaller every day. We saw that with our sample of last year's corporate anti-corruption enforcement actions from outside the United States, and enforcement actions against individuals outside the U.S. Next year's international enforcement survey is likely to include a lot more names.

*     *     *

Back in the U.S., the terrific 2015 FCPA Docket, with all known FCPA-related ongoing prosecutions, fugitives, sentencings, and pending appeals, is here.

And our 2014 FCPA Enforcement Index is here.


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.

Reader Comments (1)

Thank you, Richard Cassin, for this encouraging update and perspective.
The increasing number of places you have summarized in this posting, where those who are opposed to the historical and corrupt way of doing business, particularly international business, can meet and share experiences, is both interesting and uplifting.
I will certainly consider joining forces with one or more of them!
February 26, 2015 | Unregistered CommenterDr. David Lawson, FCIArb.
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