Richard Bistrong | Contributing Editor
Richard Bistrong spent his career as an international sales executive and currently consults, writes and speaks on foreign bribery and compliance issues from that front-line perspective.
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.
Richard was the vice president of international sales for a large, publicly traded defense supplier, which included residing in the UK and extensive overseas travel.
In 2007, as part of a cooperation agreement with the U.S. Department of Justice and subsequent Immunity from Prosecution in the UK, Richard assisted the U.S., UK, and other governments in understanding how FCPA and other bribery and export violations occurred in international sales.
In 2012, after the collapse of the Africa Sting prosecution, Richard was sentenced as part of his own plea agreement, and served fourteen-and-a-half months at a U.S. federal prison camp.
He holds an MA in Foreign Affairs from the University of Virginia.
Richard writes about current anti-bribery and compliance issues at www.richardbistrong.com. Information about his consulting practice, Front-Line Anti-Bribery LLC, can also be found on that website.
Last month, Matt Kelly, Worth MacMurray, and Leslie Benton wrote posts (here and here) for the FCPA Blog about ISO 37001 — the draft standard for anti-bribery management systems.
In the February 23 edition of the Harvard Business Review, two professors from the London Business School argue that “performance-based pay can actually have dangerous outcomes for companies that implement it.”
I recently heard a CEO at a compliance event ask, “Are people ready to sacrifice sales for compliance and ethics if that moment arises?” Great question.
The DOJ’s charges against Vincente Garcia, the former SAP regional director and head of SAP’s Premier Client Network for Latin America, are filled with advisors, consultants, agents, and channel partners. In the e-mails, they refer to one another as friends and associates, and they talk about their connection with a public official, who at the end of a long transactional road will “owe us a big one.”
The New York Times reported last week that Rajat Gupta will finish the final months of his two-year prison term for insider trading in home confinement. Whenever I hear about someone going home after serving time in prison, there is always a sense of relief that he or she has emerged from the other side of incarceration.
I want to thank those who contributed comments to my post, “Hotlines inhibit honest feedback, and other reasons people clam up.” The ideas in the post, as I shared, run counter to the conventional wisdom of why organizations deploy anonymous hotlines, and their value.
Compliance professionals often ask me how they can better communicate with their front-line teams. I usually respond, “Bring them in, ask them about the real risks they face, and the more upset you are by what you hear, the better that conversation is going.”
Tomas Clarke was sentenced to two years in prison Tuesday, following Ernesto Lujan’s two-year sentence last Friday. Sentencing might seem like the last chapter of an FCPA enforcement action. For the defendant, however, what comes next is the toughest part of all.
Thanksgiving 2012 was my worst day in prison (other than the day I self-surrendered).