In the Process Section of the August issue of Wired Magazine is an article by Mike Olsen entitled, “How Con Ed averts blackouts during a heat wave”. Being from Houston and living in one of the hottest summers on record, I was interested in how the electric company in New York City might handle a heat wave and attendant overloading of the Big Apple’s power grid. The article set out the procedures which Con Ed has in place. While noting they were “worthy of NORAD”; the article drove home to me, once again, how important to a process is a Foreign Corrupt Practices Act (FCPA) compliance program.

Con Ed has a five step process to save its electrical grid in an overload situation. These steps are: (1) Recruit, (2) Monitor, (3) Escalate, (4) Make the Call and (5) Shut it Down. These five steps can be critical in a FCPA compliance program. So if your company is in New York, New England or any other place in the United States where an overloaded power grid looms this summer (i.e.: the entire US) perhaps you might consider this process in the context of your FCPA compliance program.