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JUNE 2016



laws and their companies now use the English term “compli-

ance” as a synonym for good business ethics.

For example, the website of the Italian company Eni, which

was the subject of a major FCPA case in 2010, contains a page

entitled “Compliance Program Anti-Corruzione di Eni” (Eni’s

Anti-Corruption Compliance Program), which includes sec-

tions on third-party due diligence, top-level commitment and

Eni’s Code of Business Ethics.

In an era in which euphoria over the end of the Cold War

has been replaced by hand-wringing over the resurgence of

authoritarianism, it is useful to note the development and

spread of international consensus on good business practices

and anti-corruption. The United States can contribute to these

processes by continuing to spread the word about the FCPA and

to support international institutions like the OECD Working

Group on Bribery.

Such strategies cost little political capital, but can have a

major effect.


Many recognize that anti-

corruption compliance is good

for business: internal controls

that prevent bribery also help

companies avoid internal

fraud and embezzlement

and unscrupulous business


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