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Don't let your compliance program get 'Armstronged'

How does a good company with excellent products and a strong reputation turn into a criminal enterprise? It  takes leadership. Of the wrong kind, of course. So it was for the Lance Armstrong Team.

The evidence released in the anti-doping enforcement action, according to the New York Times, "drew a picture of Armstrong as an infamous cheat, a defiant liar and a bully who pushed others to cheat with him so he could succeed or be vanquished."

The teammates had their own culpability. It didn't seem wrong in the beginning, they said. But later, when their childhood dreams of success in a beloved sport had been destroyed by having “crossed the line,” they voiced a searing remorse for the lost moral compass.

Most cheaters do get caught. Facts don't fade away. Once the “court of public opinion” has changed, and what was once tolerated becomes outrageous, enforcement follows.

Competitors and bicycling fans wondered about Armstrong's extraordinary mountain climb in a 1999 race. Over a decade later, the facts came out: He doped it, he cheated.

Now Armstrong's legacy to compliance is about who crosses the finish line not first but best.

In the FCPA world, most cheaters get caught, even long after the bribery. A high-flying company decides to cash in by selling out to a merger partner. The due diligence exposes how the company cheated by paying bribes to get business on its exceptional climb to the top. And then there are whistleblowers, risk-based internal and external audits, and always the competitors. Any of them might one day expose the truth.

Compliance practitioners faced with cheating and trying to “market” compliance inside the company can now invoke the story of the crash-landing of Lance Armstrong and the greatest cycling team ever.

Among the questions to ask: Is our team being bullied and misled into corruption? Will we live to regret this? Was it our dream to win this way, by cheating?

The choice for Armstrong's team was either to be bullied by a seductive, charismatic leader, or to do the right thing. Down one path was ultimate failure, disgrace, and ruin. Down the other was real victory.

That's the lesson for compliance from Lance Armstrong.


Michael Scher is a contributing editor of the FCPA Blog.

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