THE FOREIGN SERVICE JOURNAL
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has been replaced by hand-wringing over the resurgence of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
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
partners.Take AFSA With You! Change your address online, visit us at www.afsa.org/address Or Send changes to: AFSAMembership Department 2101 E Street NW Washington, DC 20037 Moving?