If you thought that anti-corruption compliance was solely of interest in the most industrialized nations of the west or north, know this: the International Anti-Corruption Academy proves otherwise.
I recently had the pleasure of teaching in IACA’s new International Master in Anti-Corruption Compliance and Collective Action (IMACC) program. Imagine a room full of experienced compliance professionals seeking advanced learning and certification in anti-corruption compliance. What do you envision? I’ll guess you have it half right and half wrong.
You were right to guess their job titles: Chief Compliance Officer from a national revenue authority, Director of a financial intelligence unit, Head of Forensics and Whistleblowing at a major British bank, Deputy Director General in the Risk Management Department of another major bank, Managing Partner of a law firm, etc., etc., etc.
But I’ll bet you did not guess the countries from which they hail. Malawi. Burkino Faso. China. Zambia. Slovakia. Mexico. Togo. Afghanistan. And beyond.
Gathering in a room of anti-corruption compliance professionals, one is impressed by that which makes us different, and that which is truly universal. Their cultures, legal and economic systems, and personal experiences are wildly diverse. And yet, they share a common commitment to the anti-corruption cause.
Put another way, they all subscribe to the two tenets of the anti-corruption movement: 1) that the abuse of public office for private gain is wrong, irrespective of culture or convention or position of authority; and 2) there are things we can do to address it.
When the FCPA was first adopted in 1977, we heard a variety of objections. One was that there are places in the world where corruption is cultural. We are gradually discovering the falsehood of this view. There may be places where corruption is more prevalent than others, where citizens resign themselves to its necessity, where the prospect of its deterrence seems dim at best.
But no culture — none — teaches that a suitcase full of cash, given to a government official under the table in exchange for a benefit to which the payor is not entitled, is a good thing, such that we would not want to deter it even if we could. And so, the key is to disseminate the belief that corruption is actually something we can change — that it is not inevitable, an inherent feature of human sociality. There exist tools that have proven to work; we can gather together and share them.
But no convincing is needed for these IMACC students. Indeed, they’re the ones who will return to their countries armed with a renewed fervor and an expanded arsenal of effective anti-corruption techniques. They’ll be the changemakers.
Because anti-corruption compliance is going global.
Andy Spalding is a lecturer at the International Anti-Corruption Academy, Professor at the University of Richmond School of Law, and Senior Editor of the FCPA Blog.