Have you heard about the Goldman Sachs banker who bribed his way to a conviction?

A federal jury in Brooklyn last week convicted Asante Berko, a former Goldman Sachs executive, on FCPA conspiracy, a substantive FCPA violation, and money laundering conspiracy.

Berko managed a deal between a Turkish energy company and the government of Ghana to build a new power plant in Ghana. To win the bid, he and his co-conspirators paid more than a million dollars in bribes to Ghanaian officials, including a planned payment to the Minister of Power using the code word “Holy Reign” in their communications for the payoffs.

Berko didn’t need an outside fixer. He lied directly to Goldman’s own compliance team and moved his real conversations to a personal email account.

He laundered the money through shell companies, sham invoices, and nominee accounts.
The lesson: your biggest FCPA risk isn’t always the outsider, the third party who hasn’t been vetted. Sometimes it’s the trusted insider lying straight to your compliance function.

Goldman wasn’t charged and cooperated fully, but this shows why verification, not just trust, has to be built into how you vet high-value cross-border deals.

The Ethics and Compliance Q and A show is produced by One Stone Creative.