Have boards of directors finally begun to wake up to their role in the fight against bribery, corruption and unethical corporate behavior? Name any of the most recent corporate scandals, Wells Fargo, Uber, Equifax, and one of the first questions asked was “Where was the Board of Directors?” From the FCPA perspective, consider the Telia Company FCPA enforcement action, the largest of all time, coming in with a total fine and penalty of $965 million and the same question can be posed.



