FCPAméricas Blog

Assessing the Assessments: Using the TI Corruption Perceptions Index and other corruption risk metrics

Author: Juanita Riaño

Guest Blog Post – Today FCPAméricas features author Juanita Riaño, an Integrity Officer at the Inter-American Development Bank and former Manager of the program “Global Tools to Measure Corruption” in the Transparency International-Secretariat. The opinions expressed in this blog post are entirely those of the author and do not reflect the position of the Inter American Development Bank.

Matt Ellis posted here last week that “enforcement officials and ‘best practice’ descriptions stress that adequate anti-corruption compliance programs [should be] based in sound corruption risk assessments.”

This is easier said than done. The truth is, there is no silver bullet to assess corruption risks. Measuring corruption is tricky because corruption is clandestine in nature: how can we expect to accurately assess the magnitude of a transaction that takes place under the table, in a brown envelope, or through a series of bank transfers around the globe?

The good news is that there has been tremendous progress in the development of integrity risk indicators. In ... Read more

Going Beyond the TI Index: New tools for assessing integrity risks

Author: Matteson Ellis

Enforcement officials and “best practice” descriptions stress that adequate anti-corruption compliance programs are based in sound corruption risk assessments. Howard Sklar recently provided an in-depth look at how risk assessments can be used for maximum effect. The question remains, however: how should compliance officers assess the integrity risks presented by particular countries or industries?

Historically, companies have looked to their own experience and, frequently, to Transparency International’s Corruption Perceptions Index (the TI Index) to help identify country risk. The 2011 version of the TI Index was just launched today.

These are good first steps, but leave much to be desired. Fortunately, compliance officers have a growing number of metrics to consider when conducting such risk assessments.

The Mintz Group’s “Where the Bribes Are” Map

The James Mintz Group recently launched an online tool, the “Where the Bribes Are” Map, that measures the amount of FCPA enforcement ... Read more

Brazil: Waking Up to Anti-Corruption Compliance

Author: Matteson Ellis

I have been traveling to Brazil for more than a decade now, most often for anti-corruption work, at times for fun.

On my latest trip, I saw something new. Brazilian companies and businesspeople might be beginning to wake up to the notion of anti-corruption compliance.

This observation is not based on any empirical data. It is purely anecdotal. But sometimes there is value in what one sees and hears on the ground. Consider the following:

The Embraer Subpoena. Brazilian professionals are asking questions about the U.S. Securities and Exchange Commission (SEC)’s investigation of Embraer for potential U.S. Foreign Corrupt Practices Act (FCPA) violations. They wonder the implications of Embraer’s retention of U.S. counsel and cooperation with the SEC and U.S. Department of Justice (DOJ). They question how it can be that their own companies and business people are subject to the jurisdiction of a country located in an entirely different hemisphere. They are learning about the multi-million dollar fines and jail time commonly associated with FCPA enforcement actions. And they are learning about the compliance procedures that might have helped Embraer avoid the investigation.

In particular, Brazilians are ... Read more


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