A global wave of anti-corruption regulation has been steadily gaining momentum since it began in the 1990s. International organizations, such as the Organisation for Economic Co-operation and Development, have set their sights on fighting bribery and have successfully pressured member states to pass tighter laws. Cross-border enforcement cooperation is also on the rise. This heightened scrutiny has highlighted the importance for corporations to have globally effective anti-corruption compliance programs. Successful programs help reduce the risk of violations and may also engender a more favorable regulatory response when issues arise. In a guest article, Richard Sibery, the Leader for Fraud and Investigations with Ernst & Young LLP’s Fraud Investigation & Dispute Services (FIDS) practice, and Virginia Adams, a Senior Manager in E&Y’s FIDS practice, discuss the three basic building blocks of a best-of-breed compliance program. For additional insight from Sibery, see “Training, Certification, Due Diligence, Customs Clearance and Facilitation Payments: An Interview with Leaders of Ernst & Young’s Fraud Investigation & Dispute Services Practice
,” The FCPA Report, Vol. 1, No. 1 (Jun. 6, 2012); and “Anti-Corruption Audits, Risk Assessments, Transaction Testing and the Dangers of Petty Cash: An Interview with Leaders of Ernst & Young’s Fraud Investigation & Dispute Services Practice
,” The FCPA Report, Vol. 1, No. 2 (Jun. 20, 2012).