Regulatory Compliance No Trivial Pursuit
October 02, 2019 by Mark Dunn
If serious trivia seems like a contradiction, maybe you need to be more quizzical when it comes to anti-corruption compliance. January 4 is the one day of the year when there’s an excuse to be trivial—even in an area as serious as compliance in anti-bribery and corruption, anti-money laundering and terrorist financing, and the avoidance of forced labor in supply chains. This is because, all over the world, January 4 is Trivia Day.
As trivia goes, it’s ironic that how this day came about is lost in the comparatively recent mists of time. The meaning of ‘trivia’ as we understand it today—facts that are of little value or importance beyond their own peculiarly interesting novelty— dates to the early 20th century and use of the word as it pertains to quizzes emerged in the 1960s.
Then came Trivial Pursuit, which turned useless knowledge into a full-blown craze. It even gave trivia its own trivia: the board game was created in 1979 by two Canadian blokes who mapped out its structure in an hour, over a round of beers. Annual sales peaked in 1984 at around US$800 million. (If you’re old enough, these facts are in the small but irksome category of trivia known as “wish I’d thought of it first”.)
Some years later, someone in the United States decreed that January 4 will henceforth be National Trivia Day. It caught on, and the internet did the rest in making the concept global.
Bribery and snakes
In the area of bribery, corruption, money laundering and the like, it’s natural to assume there’s no scope for fun trivia, right? Well, not quite. While it may not constitute the proverbial barrel of laughs, it does lend itself to a bag of snakes. Three of them, actually. In northern India in 2011, a couple of farmers became so fed up with the bribes demanded to access their own tax records, they upended three sacks containing 40 snakes, including several deadly cobras, on the floor of their local tax office. Apparently, a new world record was set for in-office sprinting, although uncertainty remains as to which staff member set it.
Okay, so one snake protest doesn’t make a quiz. But how about this for a question: Which country recently elected as its president a former TV comedian who campaigned on the slogan “neither corrupt, nor a crook”? He was elected in 2015 and is still incumbent, despite several close relatives and advisers being embroiled in corruption allegations and prosecutions. If you don’t know the answer, see the *below.
If you’re still not convinced there’s a quiz in this, visit the ProProfs Quiz Maker website. It has more than a million quizzes to choose from, ranging from the Ultimate Taylor Swift Quiz, to the Are You the Type of Person Who Cheats in a Relationship? quiz, to… wait for it... the excitement is mounting... the First Quiz
For Training On Anti-money Laundering the Anti-money Laundering Policy Quiz and several others in a similar vein. The multichoice questions focus on U.S. legislation and corporate practice, but you could use them as templates for writing your own anti-money laundering/anti-corruption quiz for employees and associates in any other country, to partake in as a training and awareness-raising exercise.
Statistics constitute a sizeable continent in the world of trivia, and there’s no shortage of stats in compliance. As a case in point, let’s look at the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (commonly known as the Anti-Bribery Convention)
because—trivia alert!—2019 marks the 20th anniversary of its introduction. Party to the convention are the 36 OECD members and eight other nations. Together they constitute 81 percent of the world’s outbound foreign direct investment and 66 percent of the world’s exports. They are also home to 95 of the 100 largest non-financial multinational enterprises and all of the top 50 financial multinationals. I mean, this thing has impressive reach. And you get one guess as to which superpower is now being wooed on the edge of inclusion (**).
A few months ago, the OECD Working Group on Bribery published a report, Fighting the Crime of Foreign Bribery, in which it explained: “Parties to the Anti-Bribery Convention agree to establish the bribery of foreign public officials as a criminal offence under their laws and to investigate, prosecute and sanction the offence. The convention is the first and only international anti-corruption instrument focused on the ‘supply side’ of the bribery transaction—the person or entity offering, promising or giving a bribe.”
In its graphic summary of the convention’s achievements, the report notes that bribery is now a crime in all of its 44 member countries; and all 44 have strengthened or created corporate liability laws in compliance with commitments made under the convention, allowing them to hold companies, and not just individuals, liable for foreign bribery. Eighteen countries have introduced or strengthened whistleblower protection in response to peer evaluation reports and recommendations.
Between signing the convention in 1999 and up until the end of 2017, in a total of 20 of the countries, 560 individuals and 184 entities have been sanctioned under criminal proceedings for foreign bribery. At least 102 individuals and 247 entities in 11 countries have been sanctioned for other offences related to foreign bribery, such as money laundering or accounting. The fact that 21 of the countries were yet to conclude any foreign bribery enforcement action is an indication of the uneven spread of activity. But in a total of 30 countries, another 500 investigations are ongoing.
Laboring the point
It’s drawing a dubious bow to claim that the statistics on forced labor could constitute anything resembling trivia. But how about this: Which country’s population most closely equates to the estimated number of people in forced labor around the world?
It’s Australia, with a population of 25 million.
Similarly (and also according to the International Labor Organisation’s 2016 estimate): Which country’s population is closest to the number of children, aged 5 to 17, who are subject to child labor around the world?
At a staggering 152 million, it’s Russia. Almost one in 10 of the world’s children; 64 million girls and 88 million boys. Almost one third of these children aged 5 to 14 are excluded from any education system, and 38% of those in that age bracket are involved in hazardous work.
It makes you think, doesn’t it? And isn’t that what trivia is all about?
* Guatemala (President Jimmy Morales)
1. Download our eBook on ISO 37001 to learn how this anti-bribery and corruption compliance standard can help your organization avoid becoming a risk statistic.
2. Learn how Lexis Diligence and LexisNexis Entity Insight empower enhanced risk management.