In today’s world almost everyone is doing business with everyone else. This isn’t a bad thing, but it does mean that we are opening ourselves up to more risk and have to be that much more diligent in vetting third-parties and ensuring they are aware of and trained on our anti bribery and anti corruption policies. Transparency International’s 2013 Global Corruption Barometer provides further insight into which countries we need to pay particular attention to — as they identify the top 9 most corrupt countries in the world in 2013.
9. Zambia — 85% of residents have been asked to pay a bribe.
8. Nigeria – 84% say corruption has increased in the last two years.
7. Russia – 92% of survey respondents say public officials are corrupt (highest number of all countries surveyed).
6. Paraguay – 63% of bribes were used to speed up a service.
5. Mexico – Ranks in the top 10 countries for percent of population claiming “corruption very serious,” “public officials corrupt” and “police corrupt.”
4. Zimbabwe – More than 75% surveyed acknowledged the government is run by a few entities acting in their best interests only.
3. Venezuela – 83% of the population recognizes that corruption is very serious.
2. Mongolia – Tied for highest percent of respondents saying that corruption is very serious at 86%.
1. Liberia – 75% of residents have paid a bribe at some point.
If you work with any of the countries above, there is definitely cause for concern and you should examine your FCPA compliance initiatives to determine if they are up-to-date and running effectively. You can measure the effectiveness of your compliance program through partner-specific code of conduct attestations, partner-specific training, compliance risk assessments, surveys/questionnaires, watch-list verification, scheduled audits and transaction monitoring.