The SEC’s charging decision in the corruption case against Asante Berko, a former executive of a Goldman Sachs Group Inc. subsidiary, highlights the critical importance of having in place a robust anti-corruption compliance program and internal controls tailored to identifying and addressing corruption risk, Paul Leder, of counsel, and FeiFei (Andrea) Ren, associate, at Miller Chevalier, argue in a guest post. They detail the case and explain how Goldman’s successful rogue employee defense demonstrates the benefits for a company willing to terminate a deal when confronted with unanswered questions and high corruption risks. See “FCPA Enforcers Tout Transparency, the Defense Bar Responds” (Dec. 11, 2019).