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Friday Roundup


About time, scrutiny updates, ripple, for the record, just saying, and for the reading and listening stack. It’s all here in the Friday roundup.

About Time

After dinging companies for nearly 40 years for internal controls and risk management failures, the SEC names its first chief risk officer.

As highlighted in this prior post, if the SEC were an issuer there would be many books and records and internal controls issues within the organization.

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Compliance Professionals Should Take The Corruption Perceptions Index With A Grain Of Salt

Grain of Salt

In an annual non-event, yesterday Transparency International (TI) released its so-called Corruption Perceptions Index (CPI) (see here).  As stated in the TI release, the “CPI measures public sector corruption in 180 countries and territories, drawing on 13 expert assessments and surveys of business executives to give each country a score from zero (highly corrupt) to 100 (very clean).”

The CPI generates a lot of media coverage and is a popular tool for business organizations in ranking risk (and thus prioritizing compliance). However, for the reasons highlighted in this post compliance professionals should take the CPI with a grain of salt.

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TI’s Shaming Of Countries Accomplishes Little


I have no doubt that the individuals associated with Transparency International have a genuine interest in reducing bribery and corruption in the global marketplace.

Nevertheless, I have long had good-faith concerns (see prior posts here, here, here, here, here and here) about how TI goes about this task. The latest example is TI’s recent “shaming report” (that is my term, TI technically calls its report “Exporting Corruption – Progress Report 2018″).

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Do Corruption Rankings Actually Tell You Things You Don’t Already Know?

question marks2

For many years, Transparency International’s Corruption Perception Index (CPI) was the only game in town. (See here for why compliance professionals should take the CPI with a grain of salt).

But with each passing year it seems, there are other attempts to measure corruption and a sort of corruption index competition has developed. In other words, my corruption index is better than your corruption index and here are the reasons why.

For instance, this recent FCPA Blog post is titled “Not All Corruption Indexes Are Created Equal” and like much of what appears on the FCPA Blog the post is written by a person pushing their own organization’s product or service offering.

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Friday Roundup


Funny, also funny, corruption in the anti-corruption industry, the head of the DOJ’s FCPA Unit writes, reasons for the general increase in FCPA enforcement, scrutiny alert, asset recovery, and for the reading stack. It’s all here in the Friday roundup.


This recent FCPA Blog post asked “what’s the most important FCPA case ever” and stated: “The Africa Sting showed how far the feds would go to make a splashy FCPA case. But the final lesson was that using a big sting to concoct a supposed industry-wide conspiracy was a bad idea. The judge didn’t buy it, and neither did a couple of juries.”

Funny that the post doesn’t mention that the the person at the center of this failed, manufactured case was its current Contributing Editor and training partner Richard Bistrong.

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