corporations: A very
different game, Part 1
» Multinational companies (MNCs) must take a different approach to compliance when they are operating outside of their
» MNCs under‑resource and under‑emphasize both domestic and foreign Compliance functions for a variety of reasons.
» U.S. laws prohibiting foreign corrupt practices place western MNCs at particular compliance risk.
» The approaches currently used to prevent foreign corruption are of dubious value.
» A new, more culturally engaged approach to foreign corruption prevention is required.
The foreign Compliance function in a western
Every business in every country finds itself,
to one degree or another, under the watchful
eye of government regulators. And the
government of every country is, of course,
different. Indeed, a country’s form
of government—together with its
culture, language, and geography—
are the main differences that
distinguish one country from another.
So, it goes almost without saying
that multinational companies
must take a different approach to
compliance when they are operating
outside of their headquarters country. Unlike
such common business processes as sales,
revenue collection, accounting standards, or
commercial relationships, compliance cannot
be replicated across national borders. With
few exceptions, successfully complying with
the regulations of one country is completely
meaningless to government regulators in
Consider the impact of these differences
for a company that operates in many
countries. My favorite example comes from
China. While leading a start-up in Beijing for
a US-based multinational company, I asked
our HR director to work up a draft of an
by Duncan McCampbell
Unlike such common
business processes as sales,
revenue collection, accounting
standards, or commercial
cannot be replicated across