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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

Richard Bistrong visits Andy’s outhouse

As Andy Spalding said in his call to nature post on the FCPA Blog, “systemic corruption is not inherent in society.” But “it happens,” he said, and that’s really a “terrible way to think about bribery.”

At the front lines of international business, Andy’s reflections about real-world graft are spot on. Field personnel exchange war stories in bars and restaurants where they hang out with peers and competitors during down time. Their stories, especially in those ‘low integrity” markets, reinforce the idea that “if I don’t do it, someone else will.”

Thinking that way helps perpetuate the wrong idea that corruption is somehow normal, and here to stay.

But here’s a positive take away.

In an African country circa 2005, I made an appointment at the American embassy. It was a rough environment, and I still remember the duct tape on the front door holding up the intercom switch.

I wanted to hear from military, political and security staff about their views on my company’s export application for goods falling under the International Traffic in Arms Regulations.

The embassy staff were polite but direct: No way. They cited the human rights and corruption record of the federal police. I said if we didn’t sell the products, Country X would. “Let them. It’s not coming from us,” the embassy officials said.

I later spent fourteen months in a federal prison camp in Lewisburg, Pennsylvania for corrupt behavior, and was released in late 2013.

Today, partly thanks to the embassy staff in that African country, I view the best antibribery efforts as one decision at time.

I now know that when we leave behind the wrong perspective — “If I don’t, someone else will” — we’ve made real progress in getting ourselves out of Andy’s outhouse.


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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