Global companies face increasing corruption risks — more countries are passing anti-corruption laws and enforcement is on the rise.  With the need for more sophisticated and rigorous anti-corruption compliance programs, corporate leaders face a very difficult question — how much will it cost to comply and how much will it cost if we do not comply? Well, of course, one significant and unknown variable in this calculus is what is the likelihood of getting caught? Every actor in society weighs the benefits versus the risks – and corporate actors are no different.

Occasionally, anecdotes can be relevant to this calculus. A board member in company A also sat on a board of company B. The board member told me that company B was under FCPA investigation and after experiencing such an investigation he/she was absolutely committed to making sure that company A would never come under such scrutiny.  As a result, the board member told me that company B would do whatever it takes to make sure they had a “Cadillac” anti-corruption compliance program.

So what are the costs of non-compliance against compliance?

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