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‘My work is part of something bigger’

As I settle back at my desk in Peru, I reflect on my experience last week at the IACA’s Corporate Integrity Training program. Ten years ago I wouldn’t have imagined sharing a room with people from 25 different countries to discuss anti-corruption compliance. Our topic has gone global like never before.
My concerns as a compliance attorney in Peru and Miami are like those of the government official from Cameroon, the prosecutor from Quebec, the multi-national compliance attorneys from Poland, Mexico and China, or the private practitioners from Greece and the Netherlands. We’re all interested in using incentives, not just punishments, to motivate businesses to improve their corporate integrity.
Coming from a Peruvian family of mining engineers and being the first woman to attend law school, I enjoy returning to mining towns I knew from my youth. But I go now to provide FCPA training for multinational companies. A mineworker is often shocked to know that the laws against bribery reach all the way to his remote, small town. His face registers amazement as he slowly takes in the fact that the everyday, life-long bribery he has grown accustomed to is actually illegal under Peruvian and global laws.  
The other IACA participants told me similar stories about their anti-corruption work with locals and government officials in the Congo, South Africa, Fiji and Brazil. People don’t consider everyday bribery illegal because it is so culturally entrenched.

Some important take-away lessons from the Wittgenstein Villa experience about what matters: Cultural perceptions of corruption, the value of providing interpretative guidance tailored to each location, the effect of collective action, and the impact of rewarding good practices.
Most satisfying for me, I left the IACA knowing that corruption is being actively opposed in each of the 25 countries represented at the training. While this may be only the beginning of this effort, it is no longer the isolated problem of a single country, that is for certain. My work is part of something much bigger — and growing.


Sandra Orihuela, pictured above, is the founding partner of Orihuela Abogados SCRL. Based in Lima and Miami, the firm focuses on cross-border transactions and foreign investment in Peru and the United States, with extensive experience in mining and anti-corruption. Ms. Orihuela has a BA and a JD from the University of Colorado, and a civil law degree from Lima’s Catholic University. She can be contacted here.

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  1. I think that if we want to put an end to corruption (via sanctions, business incentives), we must first find a way to align the interests of all parties involved, government officials, companies and their competitors, suppliers, employees etc. I am not sure this is possible. Did the IACA Program touch on this subject and/or provide any incite into how this may be accomplished? My apologies if this comment is overly broad or simplistic.

  2. The alignment of interests you mention is an ideal means to solve such a complex situation. While this appears more likely at a smaller scale –such as on an industry or project basis, it may not be possible to end corruption completely, as you well point out. The IACA program addressed this subject at length, and presented various initiatives and programs that have been created with such an objective in mind. There are efforts all over the world attempting to align the interests of all involved in fighting corruption by way of collaborative action. Ultimately, the success of these efforts is intertwined with their ability to change cultural perceptions on the subject.

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