I had the chance to meet Michael Fine last spring at the Dow Jones Compliance conference in Washington DC. For those of you in the compliance arena who do not know him he has worked as a Consultant to Transparency International (TI) on the export credit agency survey/report “Export Credit Agency Anti-Bribery Practices 2010″; has been involved in Legal/drafting support for World Economic Forum “PACI Principles for Countering Bribery,” a model anti-corruption program for international business; and has made a Comprehensive study of compliance “best practices” at leading multi-national companies including corporate bench-marking reviews. In short he is someone who knows his way around anti-corruption and anti-bribery.

In the September/October issue of the SCCE Magazine we are treated to an analysis by Fine of le affaire Wal-Mart entitled “A teachable moment: FCPA lesson from the Wal-Mart experience.” While several commentators, myself included, have written or spoken about some of the lessons learned from the Wal-Mart Foreign Corrupt Practices Act (FCPA) story which was broken by the New York Times (NYT) on April 21, 2012, I found Fine’s discussion fresh and he put several points together in a manner which is of use to the compliance practitioner as a review of his or her compliance program.