James Tillen was quoted regarding an OECD report showing a broader range of corruption causes, which argues for greater initial investment in compliance programs. The report's findings analyzing successful foreign corruption prosecutions should spur chief compliance officers to take action to reduce risk because they may not understand where the big risk areas are, Tillen said. The OECD's findings confirm the need to train senior management in anti-corruption policies and practices. The fact that 80 individuals have been imprisoned for corruption can serve as the basis of a strong message sent to senior executives during trainings, he said.
Training is critically important because of the degree of nuance in anti-corruption laws. "One example is the threshold of prohibited gifts and entertainment. When is dinner too much?" Tillen said. In addition, the role third parties often play in bribes calls for more effective monitoring and screening practices. "It's both a science and an art [to craft] policies and procedures to select and monitor third parties to match your organization." Because of how costly and disruptive to normal operations these investigations can be, compliance officers should push for greater upfront investment in their companies' compliance programs, Tillen said. "There's still a long way to go [to end corruption], but we're still a lot better off" than before; these prosecutions and anti-corruption efforts "have changed the way business is done," he added.