The Spanish Flu Didn’t Wreck the Global Economy
What Is Different About the Coronavirus Pandemic?
For most of the past four decades, a recurring nightmare has plagued corporate counsels, risk managers, and the CEOs of the world’s largest multinational corporations. Ever since the U.S. Foreign Corrupt Practices Act (FCPA) was enacted in 1977, they’ve believed that somehow, somewhere, in spite of millions spent honing compliance systems and a robust anti-corruption ethos, some failure of process or principle in one of their far-flung global operations would bring the U.S. Justice Department’s criminal division knocking at their door.
“It was not terribly long ago,” the chief counsel of one of the world’s largest agribusinesses told me recently, “that we looked at corruption as a regulatory risk—something anchored in our desire not to run afoul of the FCPA. It was basically a defensive posture, and we developed processes to manage it.” But the events of the past five years have demanded a