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Views and opinions expressed in this column are solely those of the AFSA FCS VP.

Contact:

steve.morrison@trade.gov

or (202) 482-9088

FCS VP VOICE

| BY STEVE MORRISON AFSA NEWS

Countering Corruption

Commercial Service officers

are on the front lines of anti-

corruption efforts around the

world. In keeping with this

month’s

FSJ

focus on corrup-

tion, I offer a short, non-

exhaustive list of resources at

Commercial Service officers’

fingertips.

While we cannot give U.S.

companies legal advice, we

can provide themwith infor-

mation and resources on anti-

corruption issues. Check with

your supervisor if you are not

sure what next steps to take in

the case of a possible violation

of U.S. law or international

agreement.

Corruption acts as a bar-

rier to trade and is a major

concern for U.S. businesses

competing abroad. Perhaps

that is why theWorld Bank

Group’s once-a-year Ease

of Doing Business rankings

(

www.doingbusiness.org/

rankings) and Transparency

International’s Corruption

Perceptions Index (www.

transparency.org/research/

cpi/overview) receive such

attention.

If you or your clients want

to learn more about the

“gold standard” in anti-brib-

ery/anti-corruption monitor-

ing, reporting and guidance,

check out the Organization

for Economic Cooperation

and Development’s anti-

corruption (bribery) website

(

www.oecd.org/corruption/

oecdantibriberyconvention.

htm). The OECD Antibribery

Convention requires coun-

tries to criminalize the brib-

ery of foreign public officials

in international business

transactions, as we do under

the U.S. Foreign Corrupt

Practices Act.

There are also several

broader anti-corruption

initiatives and conventions,

including the United Nations

Convention against Cor-

ruption:

www.unodc.org/

unodc/en/treaties/CAC.

The U.S. government is now

also including anti-bribery

commitments in our free

trade agreements (FTA),

including most recently in

the Trans-Pacific Partner-

ship Agreement,

www.ustr.

gov/trade-agreements/free-

trade-agreements. Check

with your senior commercial

officer, regional or execu-

tive director or any of the

U.S. government resources

below for further instructions,

updates or related imple-

menting legislation in any

given country.

The U.S. Department of

Justice maintains a robust

webpage on the U.S. Foreign

Corrupt Practices Act, as

does the U.S. Securities and

Exchange Commission. See:

www.justice.gov/criminal-

fraud/foreign-corrupt-prac-

tices-act and

www.sec.gov/

spotlight/fcpa.shtml.

An excellent publication

for U.S. companies, espe-

cially small and medium

enterprises, on the FCPA is

A Resource Guide to the U.S.

Foreign Corrupt Practices Act

,

found at:

www.justice.gov/

criminal-fraud/fcpa-guidance

and at www.sec.gov/spot light/fcpa/fcpa-resource guide.pdf (information on

Commerce’s role is on pages

5-6). In addition, our Coun-

try Commercial Guides also

contain useful information on

anti-corruption resources and

initiatives.

The State Department’s

Bureau of Economic and

Business Affairs also pro-

vides information on foreign

bribery. FCPA-related issues

and questions can be sent to

EB-FCPA-DL@state.gov.

For

CS officers, questions can

be directed to Commerce’s

Office of the Chief Counsel for

International Commerce, at

occic@doc.gov

.

For more information on

how to combat corruption

generally, contact the Bureau

of International Narcotics and

Law Enforcement Affairs at

anti-corruption@state.gov.

Finally, CS’s International

Company Profile service—

with its discussion of key

officers, banking and other

financial information about

a potential international

partner—may also be a helpful

resource for U.S. companies

as they conduct their own due

diligence.

n

THE FOREIGN SERVICE JOURNAL

|

JUNE 2016

53

C. EDWARD DILLERY MEMORIAL FINANCIAL AID SCHOLARSHIP ESTABLISHED

In March 2016, Foreign Service colleagues made donations to AFSA in honor of the late Ambassador C. Edward Dillery,

longtime chair of the Scholarship Committee, who died on Jan. 23. A financial aid scholarship has been established in

his name and will be bestowed on an undergraduate student for the 2016-2017 academic year.

Born and raised in Seattle, Washington, Amb. Dillery joined the Foreign Service in 1953. In his 38-year career, he and his

family were assigned to embassies and consulates general in Japan, Belgium, Vietnam, the United Kingdom, Cyprus and

Fiji, as well as tours inWashington D.C. In his last overseas post he served as ambassador to Fiji from 1984 to 1987.

After retiring, he served for two years as AFSA vice president for retirees, taught several AFSA-sponsored Elderhostel

(now Road Scholar) courses and, for 15 years, served as both a committee chair and judge for the AFSA Scholarship Pro-

gram.

Amb. Dillery was instrumental in setting policy that fostered transparency, sound financial management and acces-

sibility. An appreciation of Amb. Dillery was featured in the

April issue of The Foreign Service Journal .

n

NEWS BRIEF