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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

ISO 37001: Let’s ask some tough questions

The debate about the ISO 37001 anti-bribery management system hasn’t gone away. Compliance professionals are still asking tough questions.

Does certification matter? Is it just PR or will it save or help the company if we have a problem? What do prosecutors really think about ISO 37001?

Those questions are uncomfortable but important.

I recently spoke with Kristy Grant-Hart. She’s the CEO of Spark Compliance Consulting and an early and articulate advocate for ISO 37001 certification.

In this interview, she talked about issues that, for the compliance community, have been a source of both confusion and controversy.


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLCIn 2010 he pleaded guilty to a conspiracy to violate the FCPA and served fourteen and a half months at a U.S. federal prison camp. He was named to Compliance Week’s list of Top Minds in 2017 and was one of Ethisphere’s 100 Most Influential in Business Ethics in 2015. He was named by Thomson Reuters in 2018 as a Top 50 Social Influencer in Risk, Compliance and RegTech.

His popular real-life compliance training video, Behind the Bribe, produced in cooperation with Mastercard, was released in 2017. To request a demo of the full eleven-minute video or a licensing fee schedule, please click here.

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  1. Richard: This was a useful and interesting discussion of the potential value of ISO 37001 anti-bribery certification; but, like many other long-time anti-corruption practitioners, I believe that this discussion will need to continue for some time from many different viewpoints.

    Thank you for continuing the conversation in a constructive manner. Best, Sharie

  2. Certainly the value of the certification is the work that goes into establishing the standards and the commitment to continuously a program. But there are numerous ways to inspire and influence a company to implement best practices. An expensive and somewhat mysterious ISO certification is just one way. Let's be honest that companies' communities (regulators, customers, vendors etc.) are not recognizing the ISO certification as essential or even helpful. How many companies have actually sought certification? This is not a misinformation problem; the market is speaking for itself. For a company that needs the discipline of a certification to get its program in order, this could be a helpful tool; however, for companies that understand best practices and have management that supports the compliance program, the ISO certification is unnecessary (perhaps until the broader community agrees that this one standard is the holy grail …. I'm not betting on it).

  3. Dear Sharie and Jay- Thank you for your comments. Sharie, I totally agree, this is a journey, and the ISO discussion is one that will be continued. But the fact that we are now having a constructive dialog on a global anti-bribery certification demonstrates how far the discussion has evolved. Jay, as you share, the market will speak for itself. The accrediting bodies are now just starting to certify practitioners, so I think we are at the first stages of seeing how (and if) this standard is embraced by multinationals. I also agree with your perspective of how "for a company that needs the discipline of a certification to get its program in order, this could be a helpful tool." Perhaps for some smaller and mid-sized entities that might be somewhat intimidated as to how to even stand up a program, this could be very a helpful departure point. Thanks again to you both.

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