Keeping Anti-Corruption Compliance Simple

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4 Responses

  1. Howard says:

    An excellent post, and fine points (you take me on just as good as Tom or Mike ever did).

    We’ll have to agree to disagree about facilitation payments. I think it’s possible to do without them. I think the “you’ll kill the business” reaction is hyperbole from the people most invested (no pun intended) in being able to make the payments.

    I also haven’t seen any data comparing results of companies that make the payments with those who don’t.

    Finally, a willingness to bribe is a willingness to bribe, and one bribe leads to a more permissive culture towards bribery.

    Just my thoughts.

  1. July 13, 2012

    […] Mike Volkov took issue with some of the pronouncements of my colleague Howard Sklar had made in a blog post […]

  2. July 13, 2012

    […] Recently, Mike Volkov took issue with some of the pronouncements of my colleague Howard Sklar had made in a blog post entitled “Who is it OK to bribe?” Mike even managed to pay me compliment by saying “let’s face it, I am no FCPA Professor, or Tom Fox, who both enjoy taking Howard on” and to demonstrate that we debate in print as well as on air, I am going to respond to Howard’s blog posting in his Open Air Blog, “Why I Hate the Case Against WalMart”. […]

  3. July 17, 2012

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