Book Review: Overcoming Global Bribery

By Susanne Schwager, CMA, CIA
June 1, 2015

As business becomes increasingly global, companies that expand their operations into new countries and territories also find themselves needing to comply with the growing number of anticorruption laws. Whether it’s the Foreign Corrupt Practices Act (FCPA) in the United States, the United Kingdom’s Bribery Act, China’s Anti-Unfair Competition Law, or myriad others, staying on the right side of the law—or rather, laws—can be a challenge. Bribery and Corruption: Navigating the Global Risks, by Brian P. Loughman and Richard A. Sibery, explains these laws, how to navigate them, and more.




After explaining relevant legislative regulations from around the world, the book outlines the aspects of the anti-bribery and corruption life cycle, which includes: set up compliance programs, policies, and procedures; conduct risk assessment; monitor the system; and perform anticorruption due diligence. Various tips are presented in each chapter, and there’s also a case study that shows how to perform a risk assessment. The fictitious “Steel Company Inc.” uses an external accounting firm to identify corruption risks and to evaluate the existing anticorruption program. One part of the case study reflects on how the forensic accounting team interviewed key personnel in various locations to identify areas carrying potential risks.


This book is valuable for those who work within companies, especially since employees share the responsibility of keeping their company in compliance with anticorruption legislation and regulations, as well as for external auditors, who ensure all bribery and corruption aspects in an engagement are covered.


As someone who works for a public service company that provides material tests and product certification services to local and international customers, I found the last two chapters to be my favorite. For the people in my organization, it’s essential that there’s no doubt about our professional integrity, objectivity, and independence. Anticorruption is a big aspect of our business culture, and, with regard to potential misconduct, we keep in mind that there are always two parties involved. Therefore, it’s important to understand the risks and red flags of each region (chapter 10) and industry (chapter 11). Knowing our markets and competitors helps sell our products, but knowing the bribery and corruption risks that originate in the various countries where we do business helps us test and possibly amend our antibribery and anticorruption systems to make sure they are sufficient and up to date.


Susanne Schwager, CMA, CIA, is head of accounting and IT at MPA NRW in Germany and is an international member of IMA. Her e-mail is s_schwager@gmx.net
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