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Richard Bistrong
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Richard Bistrong: ‘It wasn’t worth it’

During a recent anti-bribery panel in New York City, I was asked why I talk about my former corrupt behavior and the time I served in federal prison. “Why don’t you put it all behind you?” the questioner wanted to know.

One reason can be found in my own sentencing hearing.

U.S. District Judge Richard Leon spoke from the bench. He said he was “concerned about others, others out there right now who are aware of this case, who are aware of other cases in this arena and who may think they can pull off conduct of a similar nature or maybe even more egregious than that you engaged in, they need to understand that if they are caught, and even if they cooperate, they are going to do jail time because in this arena, that is the ultimate deterrence.”

Another reason I have for speaking out is a prior post on the FCPA Blog. Senior editor Andy Spalding asked: What exactly are we trying to deter? How do we go about deterring it?

Prof Spalding referred to three variables people consider when deciding to engage in a corrupt transaction or to refrain from it: the likelihood of being caught, the severity of the punishment, and its swiftness.

What Judge Leon and Andy Spalding said remind me often of something important to remember: Deterrence only works if you know about it.

I think of company personnel operating on the front-lines of international business, far from the home office, in remote and often unsupervised territories. How do they get the message that real-world crime leads to real-world consequences?

How about this: It wasn’t worth it. Whatever I thought I might have gained during my corrupt journey pales in comparison to the impact of incarceration. Try being a parent, a spouse, a friend with just 300 minutes of phone time a month.

While 14 months in prison is on the low side of criminal sentencing, and I remain grateful to the government and Judge Leon for considering my cooperation and rehabilitation in the sentencing process, my reflection remains the same: it was an awful experience.

So for those in the field, the next time you’re struggling with corruption, trying to protect your bonus, thinking that you won’t get caught, and even if you are caught that “it won’t be that bad,” here’s my recommendation: Call home.

Reach out to a loved one, a family member, a trusted friend, a spiritual advisor. Listen to their voice and ask yourself if the perceived benefits of paying a bribe to win or keep business for your company are worth losing those bonds.

Then call compliance!


Richard Bistrong is CEO of Front-Line Anti-Bribery LLC. He consults, writes and speaks about compliance issues from his experience as an international sales VP and conviction for violating the FCPA, where he pleaded guilty and served fourteen and a half months in prison. He can be reached via his website, twitter and email.

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  1. Richard —

    Your post confirms again what we all hoped could be said to be true — that people can change, can learn from their mistakes and can become better from bitter experience. The saddest aspect of the many investigations I've completed for corporate clients over the years is responding to the white knuckle fear that those who were responsible in one way or another for the bribes that were paid show when being interviewed. They often seek refuge, of course, in the purported belief — mistaken or not — that they simply did what the company — or their superiors — wanted them to do. Even conducting such interviews in the gentlest way possible, which I always try to do, I've had people break down during the interview, most often at the point they realized that they did something that cannot be justified. And as the human toll mounts, there's little the company can do to protect them even if, as sometimes is true, their company superiors want to protect them. The message of your post is right on — just don't do it, it's not worth it. That's so even if one ignores, as one should not, the fact that those whose governments are infected with bribery are the most immediate — and direct — bribery victims.

  2. Part of the problem with corporate compliance programs is that they have a tendency to only punish those who get caught rather than reward and reenforce those who take care to conduct business with integrity and honor.

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