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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

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

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Do you believe in compliance miracles?

Five short years ago, the idea that any serious discussion about global enforcement trends would have to include news from China and India would have been laughable. Those countries stood not for enforcement but for uncontrolled and unpunished graft. Today — against all earthly odds — they’re fast becoming global leaders for anti-corruption compliance and enforcement. That’s gotta be a miracle.

About 70 senior compliance professionals who met Friday at the Marina Bay Sands in Singapore heard some stunning news. The speaker from India was Russ Stamets, an FCPA Blog contributing editor. And from China, it was Sun Hong, a Shanghai-based partner at Norton Rose Fulbright.

They talked about politicians, regulators, prosecutors, and regular folks in India and China who — with confidence, enthusiasm, and a sense of destiny — are leading the fight in their countries against graft. It’s not a passing fad, Russ and Sun said. It’s real, and there’s no turning back.

The Singapore confab, part of the International Compliance Leadership Series (some photos from the event are here), was a discussion about big trends in global enforcement. How about this for a big trend: MNCs no longer have one set of compliance practices for most of their markets but another for India and China.

For decades, some of the world’s best known companies with the most admired brands “made allowances” for the way they did business in India and China. With more than two billion people between them, India and China were markets that couldn’t be ignored. But to reach them, MNCs believed they had to play by local rules. And that always meant greasing some palms.

Grease palms in India or China now and expect something entirely different, the speakers said. First, you’ll probably get caught (the whistleblower culture has also gone global, after all). And second, you and your company are likely to be prosecuted and possibly ejected from the land.

Thanks to authentic shifts in attitudes and practices in India and China, global compliance programs are now . . . global. Goodbye and good riddance to one set of compliance practices for some parts of the world and another wink-and-nod set for India and China. That two-tiered way of doing business undermined the idea of global compliance and compromised and degraded the role of compliance officers.

Listening Friday to Russ Stamets and Sun Hong, we realized that compliance miracles can happen. And — apologies to Al Michaels — that one just did.


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

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