Back in 2016, I took the moniker of “The Compliance Evangelist”. I did so because since 2010 I have written about the nuts and bolts of anti-bribery and anti-corruption compliance programs. In 2011, Howard Sklar introduced me to the world of podcasting when he asked me to join him on the original version of This Week in FCPA. That led to me starting my own podcast, The FCPA Compliance Report, and later founding the only podcast network, the award-winning Compliance Podcast Network. In short, I have used social media as a platform to talk about many aspects of anti-corruption compliance, the practice of compliance and provide solid information for the compliance practitioner.
I took the moniker and continued to evangelize (in ancient Greek – bringer of good news) because compliance is the way that I can help fight the global scourge of bribery and corruption. The United Nations (UN) estimates that over $3 trillion is lost annually to the global scourge of bribery and corruption. Every day, in everything I do to bring the good news of compliance, I feel like I am helping fight the good fight in a small way.
I often cite to the story by former Secretary of Defense Robert Gates, who wrote in his memoirs, entitled “Duty: A Memoir of a Secretary at War”, “In a private meeting, the king [King Abdullah of Saudi Arabia] committed to a $60 billion weapons deal including the purchase of eighty-four F-15’s, the upgrade of seventy-15s already in the Saudi air force, twenty-four Apache helicopters, and seventy-two Blackhawk helicopters. His ministers and generals had pressed him hard to buy either Russian or French fighters, but I think he suspected that was because some of the money would end up in their pockets. He wanted all the Saudi money to go toward military equipment, not into Swiss bank accounts, and thus he wanted to buy from us. The king explicitly told me saw the huge purchase as an investment in a long-term strategic relationship with the United States, linking our militaries for decades to come.”
I would ask you to consider just how many US interests can be identified in the above quote? I can identify at least five: (1) US security interests; (2) US foreign policy interests; (3) US military interests; (4) US economic interests; and (5) US legal interests as reflected in compliance with the Foreign Corrupt Practices Act (FCPA). For any person or business interest that does not think that the FCPA has a positive aspect, I would commend you to Gates’ quote, buried at page 395 of a 618-page book, did not even merit an entry in the Index. Yet, I find it to one of the finest, clearest and most concise affirmations of the positive power of anti-corruption compliance. Anytime you face criticism of your compliance program, a senior executive wants to know why you need resources to comply with the FCPA or you hear a business colleague whining about how ‘those people’ do business corruptly, I would suggest that you read them this quote to show the power of the compliance in international business.
Everyone has a role in the fight against the bane of bribery and corruption. Certainly the regulators have a role in enforcing the law, just as others have a role in commentary and critique of those regulators, at least in a democratic society. Yet because there is a business solution to this problem, there will be companies that provide those business solutions. That is how a market economy works in a free society; there is a business need and the market moves in to fill that need. In the case of anti-corruption compliance, that need can range from legal services to technological solutions.
But now we have a new story and a new reason to fight bribery and corruption. Last week, President Biden announced, “Corruption is a risk to our national security, and we must recognize it as such. Today, I am issuing a National Security Study Memorandum on the Fight Against Corruption to establish combatting corruption as a core U.S. national security interest. With this Memorandum, I am directing departments and agencies to make recommendations that will significantly bolster the ability of the U.S. government to combat corruption.”
This means that all of us can join in not only the fight against the international scourge of bribery and corruption but now can directly join the fight against national security risks. The Gates story demonstrates the power of a business solution to the legal issue of corruption. But now this role has expanded into a national security matter. So, I will expand the role that I evangelize upon, the business solution to the legal problem of bribery and corruption across the globe, to include US national security interests. I will evangelize through commentary, current events and compliance know-how. I will continue to use the ever-expanding world of social media to bring this compliance evangelism forward.
But you can join me in this evangelism. Every person who posts a Tweet about compliance or retweets such a post, who writes a piece on LinkedIn about compliance or shares someone else’s post is evangelizing about compliance. As important as I thought compliance was before President Biden’s statement, due to the direct link between corruptioncrimeterrorism; the President’s Statement has now made that linkage a national security issue for the US. I hope that you will take part in this evangelism with me. One person may move the ball forward a little each day but collectively we can all move the needle by talking, writing, blogging, tweeting (and using all other forms of communication) to bring the good news of compliance forward. I hope you will join me in this crusade. Everyone can be a Compliance Evangelist.
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