Abstract
Picture this: A Fortune 500 company discovers that its star salesperson has been making “facilitation payments” to foreign officials for years. Upon a closer look, these payments turn out to be illegal bribes under U.S. law. The company’s General Counsel turns to the Chief Compliance and Ethics Officer and asks, “How did we miss this?” This scenario illustrates why the legal profession needs more lawyers who understand not just how to respond to problems, but how to prevent them.