In an article in Monday’s New York Times (NYT) entitled “At I.M.F, a Strict Ethics Code Doesn’t Apply to Top Officials”, Graham Bowley reported that there are two separate sets of ethics guidelines; one for the 2400 “rank-and-file staff and another for the 24 elite executive directors who oversee the powerful organization.” The article sets forth this dichotomy and is a very useful review for any company subject to the US Foreign Corrupt Practices Act (FCPA) or UK Bribery Act on what NOT to do regarding their anti-bribery and anti-corruption program.