FCPA: How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)

Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the Sicilian Invasion. Herodotus wrote about the beginnings of the Golden Age of the Greek City State through the defeat of the Persian Invasion of Greece. Slogging through both is never easy but it is far and away worth the effort. One of the things that both of these ancient authors wrote about was massive change.

I recently read a book review of a couple of new volumes which looked at these authors and thought about the changes wrought when implementing or enhancing a Foreign Corrupt Practices Act (FCPA) compliance program. In making a large change, most compliance practitioners think of bringing it all to a company in one fell swoop. This is usually based on a Board of Directors or senior management directive to ‘get it done’. Sometimes this can simply be overwhelming to the compliance practitioner or information overload to the troops in the field, particularly those outside the US. However, a recent article in the MIT Sloan Management Review, entitled “How to Change an Organization Without Blowing It Up”, suggests that a different approach might be appropriate. In this article, author Karen Golden-Biddle writes that there is a middle ground between wholesale change and tentative pilot projects which could allow an organization to operate more effectively.

The author believes that “Too often, conventional approaches to organizational transformation resemble the Big Bang theory.” Further, that this “Big Bang transformation attempts often fail, fostering employee discontent and producing mediocre solutions with little lasting impact ...

Zum vollständigen Artikel

Cookies helfen bei der Bereitstellung unserer Dienste. Durch die Nutzung erklären Sie sich mit der Cookie-Setzung einverstanden. Mehr OK