Review of Gemma Aiolfi’s Anticorruption Compliance for Small and Mid-Sized Organizations

For almost two decades the Basel Institute on Governance has advised corporations large and small, first in Europe and now around the globe, on how to develop a robust anticorruption compliance program. One that will prevent the company from becoming entangled in a corruption scandal while at the same time neither compromising its ability to compete nor dampening its entrepreneurial energy. Gemma Aiolfi, who has headed the Institute’s corporate compliance work for the last seven years, presents the Institute’s collective experiences in a new volume from Elgar, Anti-Corruption Compliance for Small and Mid-Sized Organizations.

What sets Aiolfi’s book apart from the many fine volumes already on the market (examples here, here, and here) is that it is leavened with literally dozens of examples drawn from the Institute’s work. How should a company establishing a compliance program handle personnel used to doing business “the old way”?  What should a manager do if she discovers police in a developing country are threatening to shut down critical operations if the company’s low-level frontline personnel don’t pay them off? How should a company deal with senior government officials’ requests for lavish travel and entertainment allowances when visiting a company’s operations? Discussions of how to handle each, with suitably anonymized case studies explaining how management actually dealt with them, is what makes the volume so useful.

Continue reading

Commentaries on Corruption and the Coronavirus Pandemic: Update

A couple weeks back, I said I was thinking about trying to collect and collate the ever-increasing number of commentaries on the relationship between corruption and the coronavirus/COVID-19 pandemic. Several readers wrote to encourage me to continue, so I’m doing another update. I’m not sure how long I’ll be able to keep this up, since commentaries in on the corruption-coronavirus connection, like the virus itself, seem to be growing at an exponential rate. I certainly don’t make any claims to comprehensiveness (and thus I beg the forgiveness of anyone whose contributions I’ve neglected to include in the list below). But here are some new pieces I came across, followed by a chronological list of corruption-coronavirus commentaries to date: Continue reading

Some Recent Commentaries on Corruption and the Coronavirus Pandemic

As I noted last week, although this blog is going to keep on going during the COVID-19 crisis (though perhaps with somewhat reduced output), it’s a bit challenging to proceed with blogging about one problem (corruption) when another problem (the COVID-19 pandemic) is so much at the forefront of everybody’s mind. And in that last post, I noted that although there’s a well-known connection between corruption and public health generally, “so far corruption doesn’t seem to be a major issue in the COVID-19 situation.”

I think perhaps I spoke too soon. We’re already starting to see a number of interesting and useful commentaries on the connections between corruption/anticorruption and the COVID-19 pandemic (several of which readers helpfully noted in comments on last week’s post). I do think we should always try to be a bit cautious about straining to find links between whatever it is we work on and the most salient problem of the day. (I can’t help but remember that in the aftermath of the 9/11 attacks, people suddenly discovered that whatever problem they’d been working on for the past decade was inextricably linked to the threat of global terrorism.) But in this case I’m persuaded that the links are particularly plausible and important that this is something that deserves further study.

At some point, I may post some original content on this topic to GAB, but for now let me just provide links to some of the interesting early commentaries on the possible connections between corruption and the COVID-19 pandemic:

  • Natalie Rhodes, who works with the Transparency International Health Initiative, has an essay–subsequently expanded into a longer feature on Transparency International’s website–discusses some of the corruption risks during the response to an epidemic, including shortage-induced bribery risks, diversion of emergency response resources, and kickbacks in the procurement process.
  • Jodi Vittori, a fellow at the Carnegie Endowment, has a piece entitled “Corruption Vulnerabilities in the U.S. Response to Coronavirus,” which similarly emphasizes corruption risks in medical supply chains, and the greater difficulty in securing transparency and accountability during times of crisis. She lays out a series of measures that, she argues, must be integrated into all COVID-19 response legislation, and also suggests some things that ordinary citizens can do.
  • Another Carnegie Endowment fellow, Abigail Bellows, has a piece called “Coronavirus Meets Corruption: Recommendations for U.S. Leadership,” which emphasizes that the combination of systemic corruption and the COVID-19 crisis could prove especially devastating in the developing world, and suggests that the U.S. government could help ameliorate this situation by targeting more of its foreign aid at strengthening fiscal management systems, and by enacting a number of currently-pending bills that, while not specifically related to corruption in the health sector, would provide greater U.S. support to the fight against kleptocracy abroad.
  • In one of the earliest blog commentaries suggesting a corruption-coronavirus link, Gretta Fenner and Monica Guy of the Basel Institute on Governance wrote a post for the FCPA blog in late January that suggested the original coronavirus outbreak in China may have been linked to the illegal wildlife trade, and that the illegal wildlife trade is made possible by corruption–a string of connections that leads them to ask, in the title of their post, “Did corruption cause the deadly coronavirus outbreak?”

I’m sure that in the days and weeks ahead, more commentaries will appear that explore both the ways that corruption may have contributed to, or exacerbated the impact of, the coronavirus pandemic, and the corruption risks associated with the policy responses to this crisis. I probably won’t be able to keep up with all of them, but I’ll do my best to feature them on the blog when I can, and if readers are aware of other useful commentaries, please send me the information through this blog’s contact page.

Thanks everyone, and stay safe.