In many compliance programs, there is a tension between focusing on fostering a compliance culture on the one hand and setting forth – and enforcing – rules to guide employee behavior. In a guest article, Anna Romberg, executive vice president of legal, compliance and governance at Getinge, a Swedish life sciences company, and Ann Sultan, a member at Miller & Chevalier, explore the differences between rules-based and culture-based approaches towards ethics and compliance, drawing on their experiences working with U.S. and European companies, and also note differences in the application of ethics and compliance programs depending on geographic orientation. See “A Comparative Look at COVID-19 Corruption Risk and Response in Latin America and the U.S.” (Aug. 5, 2020).