Experts Speak Out on Common Anti-Corruption Challenges


The Wall Street Journal’s Risk & Compliance Journal recently partnered with Deloitte to report on Chief Compliance Officers (CCO’s) most common anti-corruption challenges. These include gaining C-suite buy-in for anti-corruption compliance programs, and innovative compliance strategies, among other topics. 

A panel of experts discussing the challenges included: 

  • Kathryn Cameron Atkinson, member and chair, International Department at Miller & Chevalier; 
  • Gary DiBianco, partner, Government Enforcement and White-Collar Crime with Skadden Arps, Slate, Meagher & Flom LLP; and 
  • Jonathan Drimmer, partner, Investigations and White-Collar Defense, Paul Hastings LLP. 

DiBianco noted that managing third-party vendors can be one of the most monumental challenges for anti-corruption compliance in large corporations. He pointed out corporations who have not been through a corruption investigation or settlement often have more difficulty in effectively managing third parties. 

Although CCOs increasingly recognize the importance of risk-based diligence and onboarding, it can be difficult to implement because it requires coordinated efforts among various groups including procurement or vendor management, finance, legal, and compliance,” DiBianco said in the Wall Street Journal article. “CCOs are more apt to succeed when they can identify the subset of vendors who may present compliance risks, and then implement an onboarding system that requires enhanced diligence and review of that group. 

To learn more CCO’s most pressing anti-corruption challenges, please consider reading the Wall Street Journal article Or to understand how MCO can help organizations address these challenges, view our Anti-Bribery and Corruption Solutions.