***** Bribery and Corruption: Navigating the Global Risks. By Brian Loughman and Richard Sibery. John Wiley & Sons, www.wiley.com; 432 pages; $75.
Bribery and corruption in international business have been part of national cultures for as long as individuals have traded goods and services. Today, hundreds of billions of dollars a year are sidetracked to corrupt individuals, officials, and expeditors so that companies and corporations can receive favored treatment for contracts overseas. The authors of this book focus on educating business leaders and employees about how to avoid corrupt practices, and they do it very well.
Authors Loughman and Sibery, partners in the Ernst & Young accounting firm’s fraud investigation and dispute services practice, have successfully created a clear, well-organized, and readable desk reference for corporations that do business internationally. They have addressed in detail statutory definitions and elements of proof, exceptions and affirmative defenses, records requirements, internal financial controls, risk assessments, audits, and due-diligence provisions that are the core of strong anticorruption compliance programs. The United States’ Foreign Corrupt Practices Act is addressed in detail, and the United Kingdom’s Bribery Act is also discussed.
Nothing is better than an explanation, in commonsense terms, of how to establish and monitor a good anticorruption compliance program. The authors do this superbly, and serious readers would do well to follow their expert advice. What makes this book most interesting is the authors’ discussion of worldwide regional considerations. They provide country-by-country examples of companies that have been involved in and found guilty of corrupt practices. They stress that knowledge of regional legal and enforcement practices is most important to ensure business compliance with those requirements. Other aspects addressed are the risk factors, broken out by industry, presented with the authors’ mitigation recommendations.
Of concern is that the authors used only Ernst & Young employees to provide input. Neither the authors nor contributors had certifications in fraud investigation. Thus, the text is the reflection of the internal training and investigative experiences of Ernst & Young personnel only. That said, this well-written book certainly provides security managers and directors who have internal financial investigatory and program responsibility with expert guidance. The challenge for those responsible will be to present the authors’ message to organizational leaders for implementation and compliance support.
Reviewer: James T. “Tom” Roberts, Jr., CPP, FEMA PCP (Professional Continuity Practitioner), president of Starboard Focus Continuity Planners, has served ASIS as a chapter chair, regional vice president, national council chair, and member of the Professional Certification Board and Item Development Group. He currently serves on the ASIS Law Enforcement Liaison Council and serves as the LELC-IACP liaison committee chair.