Bribery and Corruption: real-world risks and lessons of corporate compliance
- Tuesday, 26 November 2024
A highly anticipated panel discussion on bribery, corruption, and corporate compliance took place at Middlesex University (MDX) Dubai on Monday 25 November 2025, bringing together experts to explore the challenges and opportunities organisations face in combatting corruption.
The session focused on the story of Richard Bistrong, CEO of Front-Line Anti-Bribery LLC, and how in 2009 he was imprisoned for 18 months after being charged with violations under the Foreign Corrupt Practices Act (FCPA).
The panel also featured the man who led the investigation and brought the charges against him, Ronald Machen, former US Attorney and now partner at WilmerHale. The panel was completed by former special agent for Homeland Security and current president at Guidepost Solutions, John Torres, and moderated by Elvis Angyiembe, Co-Founder and Co-Chair of the MEACA Compliance Association.
Richard spoke candidly about the pressures he faced early in his international sales career, when he was confronted with the decision to either comply with ethical standards or secure business success through third party bribery.
He highlighted the “slippery slope” that begins with seemingly small ethical compromises and stressed the importance of company CEOs setting the tone for compliance throughout the organisation. Richard was involved in trade and FCPA violations that led to him, when confronted by Ronald and the Department of Justice, co-operating with law enforcement, mitigating his sentence and resulting in many others being imprisoned.
The panel discussed how workplace risk and the commercial mindset have evolved since Richard’s prosecution. While certain challenges remain, there have been significant changes in the expectations regulators have of corporations, emphasising the critical role that business leaders, particularly the C-suite and Board, must play in ensuring compliance. The importance of well-designed compliance programmes was also highlighted, with the panel noting that such programmes must not only exist on paper but also be functional in practice.
Ronald spoke about how compliance is about more than just training employees to understand the rules; it is about instilling a culture that prioritises ethical behaviour and ensures that everyone from the ground up is aligned with the company’s values.
John discussed the growing sophistication of compliance tools, including programmes that track cryptocurrency transactions, and the importance of staying ahead of new forms of financial crime. He also pointed out the significance of involving the people operations team in compliance efforts.
During the event, Professor Tenia Kyriazi, Deputy Director of Teaching & Learning, Law and Sciences Head of Law and Politics at MDX Dubai, said: “Thank you to our guests for such insightful contributions. It is events like this that make a difference, as they put laws and regulations into a practical perspective for students and the wider community.
“Universities have an instrumental role to play in fostering a culture of compliance and ethics and I am happy that, our students, future compliance officers, are attending this event today.
“At Middlesex University Dubai, we are committed to offering a holistic education that exposes students to the real world and engages them with professionals and the wider community.”
The session was organised by Samantha Roberts, Head of the Juris Centre of Excellence for Legal Education and Training, CPC Undergraduate Law & Politics, in partnership with the Middle East and Africa Compliance Association (MEACA).
Juris provides a platform for a wide range of quality legal education initiatives and professional training activities across the region and internationally, connecting students with leading industry professionals. Are you interested in studying law at MDX Dubai?
