Richard Bistrong FCPA Real-World Blogger and Speaker


New York Metropolitan Area, United States

Contact: Richard Bistrong

Third Parties and the Red Flags You Don’t See

Recently, I was reading a White Paper by Dun and Bradstreet titled “Anti-Bribery and Corruption Compliance for Third Parties: Is an off the shelf product enough?”. As the D&B paper points out, “the risks of insufficient…more
| Commercial Law & Contracts

EY Fraud Survey & Compliance Fatigue. Do as I say not as I do.

A few weeks ago I posted “EY Global Fraud Survey: “Depressing,” yes, surprising, no” and shortly thereafter, Philipp Kloeber, Consultant at Ernst & Young, Melbourne, Australia was kind enough to refer me to the EY paper…more
| Antitrust & Trade Regulation, Business Organizations, Criminal Law, International Law & Trade

Corruption, Risk and Business Strategy. Which one manages the others?

Since I stared writing about issues relating to compliance at the front line of international business, I have found myself looking more and more at the role of business strategy as a significant foundation of anti-bribery…more
| Commercial Law & Contracts, International Law & Trade

EY Global Fraud Survey: “Depressing,” yes, surprising, no.

In an August 21, 2014 post concerning the Ernst and Young (EY) 12th Global Fraud Survey (link here for download), Cindy Knezevich, (Vice President of Marketing Operations at The Network), states, “it’s shocking how little…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

Bribery & Deterrence: A Tale of Two Sentences

In an August 11, 2014 article (www.thebirberyact.com) “Supersize me: Innospec 4 sentencing remarks do much more than they say on the tin,” Barry Vitou and Richard Kovalevsky (“The Authors”) do a great service by elevating the…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

A solid business strategy as the foundation of Anti-Bribery Compliance

Ethical Boardroom was kind enough to ask me to share my thoughts on what management techniques exist for promoting a cost effective FCPA or UK Anti-Bribery program across a global organisation. Clearly, there is no shortage…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

Corruption, Regime Change & Risk

Recently, I have been reading and blogging on a number of different papers, guides and articles that deal with the challenges of foreign bribery and third party intermediaries. While each work has been interesting, compelling…more
| Commercial Law & Contracts, International Law & Trade, Government Contracting

Deterrence: You had me at "being caught."

At my sentencing hearing, Judge Richard Leon stated that he had no doubt that I had been ultimately deterred, and added "Have you made a turn in the road for the better? There is no question about that either. But I have to be…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

What happens when business strategy becomes a red-flag for bribery?

Richard Bistrong spent much of his career as an international sales executive. He was the Vice President of International Sales for a large, publicly traded manufacturer of police and military equipment, which included residing…more
| Commercial Law & Contracts, Criminal Law, Labor & Employment Law, International Law & Trade

“Countering Small Bribes.” A Personal Perspective on the Guidance by Transparency International

First, whenever I read a paper, book or guidance about “how to pay a bribe,” or “how to avoid a bribe,” etc., it is always with some degree of skepticism. I often wonder how an organization or person can have a perspective on…more
| Commercial Law & Contracts, International Law & Trade

The Illusion of No Victims: The Final Component of “Rationalizing Bribery.”

As Andy Spalding, Assistant Professor at the University of Richmond School of Law and Senior Editor of the FCPA Blog stated in a recent guest post on The Global Anticorruption Blog, “Most of us would agree that overseas bribery…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade

Corruption & Procurement: Bribery "Thrives in the Dark."

In the July 31, 2014 edition of the Jakarta Post there was a featured article “Smith & Wesson bribery scandal involves National Police officers,” which reported that “the Indonesian Corruption Watch (ICW) has called for an…more
| Commercial Law & Contracts, International Law & Trade

Is Anti-Corruption a Business or Legal Issue?

On June 5, 2014, Philippe Montigny, President of Ethic Intelligence (www.ethic-intelligence.com) asks exactly that question in an editorial. My own perspective of compliance remains much along the lines of those such as Mr…more
| Commercial Law & Contracts, International Law & Trade

Rationalizing Bribery: Corruption Has No Witness.

This is part three of my four part series on how I "Rationalized Bribery." It addresses the reality that there are usually no witnesses to overseas discussions involving an actual or potentially corrupt transaction…more
| Commercial Law & Contracts, International Law & Trade

Benchmarking Bribery and Corruption: "Vet it and forget it."

On my own "must read" stack has been sitting the "2014 Anti-Bribery and Corruption Benchmarking Report, Untangling the Web of Risk and Compliance," ("ABC Report") by Kroll and Compliance Week. While I have read a multitude of…more
| Commercial Law & Contracts
Showing 1-15 of 20 Results
|
View per page
Page: of 2
Areas of Practice
  • Ethics & Compliance
Locations
Other U.S. Locations
  • Connecticut
  • Massachusetts
  • New Jersey
  • New York
This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.