Coalition for Integrity

Jeannette Chu and the National Foreign Trade Council were very kind to host and participate in yesterday's kick-off event. Our discussion with Arthur Mok on the operational aspects of US companies reshoring from China was a strong start to Coalition for Integrity's webinar series on this broad topic. Complexities, nuances, and governmental pressures abound, making thoughtful risk mitigation strategies (including addressing corruption risk) that much more important. The April C4I webinar event in this series will review the practical and legal considerations involved with reshoring from China to two popular alternative locations: India and Mexico.

"Reshoring from China: Practical and Legal Considerations for US Companies." Among the questions to be considered at this upcoming event are: What are the leading practices being used by US companies as they de-risk China supply chain reliance through acquisitions elsewhere in Asia, disengage gradually, and/or pursue other “China + 1” strategies? How have Chinese suppliers adapted to the “reshoring” trend among US companies? What are the local law considerations as US entities depart from or downsize operations in China? ? COME JOIN US: On Tuesday, March 18, 2025, Coalition for Integrity (C4I) is holding a hybrid event with the National Foreign Trade Council (NFTC) and Ropes & Gray LLP to consider these and other related issues. Jeannette Chu, John Pickel, Arthur Mok, and Worth MacMurray will speak. The event will take place online and in person at NFTC's offices at 1225 New York Ave. NW - Suite 650B, Washington, DC, and will run from 11 AM to 12:15 PM. Lunch will be provided after the event for in-person attendees. Please contact Worth MacMurray at [email protected] by noon on Monday, March 17, if you would like to attend online or in person – and please understand that space is available on a ‘first come – first served’ basis. This event is closed to the press.

On March 18, 2025, Coalition for Integrity (C4I) is holding a hybrid event with the National Foreign Trade Council and Ropes & Gray LLP on the topic of "Reshoring from China: Practical and Legal Considerations for US Companies". Panelists will include NFTC's VP National Security Policy Jeannette Chu and Senior Director, International Supply Chain Policy John Pickel, as well as Arthur Mok from Ropes and C4I CEO Worth MacMurray. The event will take place online and in person at NFTC's offices at 1225 New York Ave. NW - Suite 650B, Washington, DC, and will run from 11 AM to 12:15 PM. Lunch will be provided after the event for in-person attendees. Please contact Worth MacMurray at [email protected] by noon on Monday, March 17, if you would like to attend online or in person – and please understand that space is available on a ‘first come – first served’ basis. This event is closed to the press.

C4I Statement on the Feb. 10, 2025, Executive Order Pausing FCPA Enforcement ___________________________ The Coalition for Integrity (“C4I”) believes that the pause in U.S. enforcement of the FCPA hurts rather than helps American global competitiveness and national security. A pause risks, among other things, undermining the competitiveness of U.S. companies in international markets, disincentivizes the enforcement of counterpart laws by other countries, and erodes the anti-corruption leadership position of the United States around the world. Furthermore, U.S. companies will now operate in an emboldened global bribery threat environment – where our competitors and adversaries will likely leverage (and even trumpet) that America’s FCPA enforcement resources have been publicly diverted to other priority areas. The FCPA remains the law of the United States.?It applies to and has been enforced against U.S. companies and non-U.S. companies with ties to the United States. American companies for a variety of technical (e.g., applicable statutes of limitation and overseas laws) and practical (contractual and business standard obligations) reasons will have no choice but to maintain anti-bribery compliance programs. Many U.S. companies will continue to sustain strong compliance programs because experience has demonstrated that they are good for business by promoting fairness and a level playing field (helping ?to reduce fraud and theft, and protect their employees, and are consistent with their corporate values). Business leaders involved with C4I have also seen that the FCPA is a positive U.S. competitive differentiator in global markets. It actually strengthens their companies’ reputations. Foreign officials and regulators are less tempted to solicit bribes when US companies can credibly respond that they are prevented from offering bribes by strongly enforced U.S. laws. This edge can be especially important for smaller US companies with limited resources, and for those larger companies that are engaged in capital-intensive long-term business investments and operations abroad.?In addition, bribery adds to the cost of doing business. Active U.S. enforcement also serves to pressure other countries to properly enforce their FCPA-like laws against their own companies.??Having a law on the books is not enough.?In recent years, pressure from the U.S., the OECD and others have caused a number of countries to step up their enforcement efforts.?While more needs to be done in this regard, a step back by the U.S. from FCPA enforcement sends the clear message to other countries that they can do the same. C4I would welcome the opportunity to work with policymakers and business to provide specific actionable suggestions for how the Administration can improve the FCPA to better fight bribery, consistent with U.S. and global interests.

A second set of observations from my recent trip to Cuba: Cuban sugar production: more sugar is now imported annually (with a smaller population) than Cuba exported as the world’s largest producer during the 1960s to 1990 (4 – 8 million tons per year) to the Soviet Bloc at 4 times the market price. Cuban “justice”: 25 years in jail for slaughtering a state-owned cow, wandering unsupervised around the countryside, to feed one’s family, and 15 years for murdering a spouse. Cuban “political participation,” offered only somewhat tongue-in-cheek by a Cuban friend: on matters put to a vote in the National Assembly, 50% of those present vote ‘Yes’, and the other 50% votes ‘Yes, absolutely!’ This educational visit centered around Cuban culture and the arts. Young artists spoke of difficulties obtaining basic art supplies, as well as food. Project collaboration is problematic. Colleagues leave suddenly and without prior notice to friends or coworkers (the prevailing practice) for opportunities outside the country. I had abundant preconceptions of Cuba – from a gap year spent living in then-Communist Chile and hitchhiking throughout Latin America, and continuing with a Latin American studies college concentration, a lengthy Haiti anti-corruption project, and many other professional and family trips to the Latin American and Caribbean regions. Briefly experiencing Cuba has added contextual depth, unexpected perspectives, and so many more questions.

I was in Cuba earlier this month. So close. So beautiful. So dysfunctional. My first set of observations: Cuba’s demographics are bad, getting worse, and unsustainable. Over one million (primarily educated, skilled, and urban-dwelling) people have left the country in the last two years. The 10 million plus population also declines because of a low birth rate and a climbing median age that is among the highest in Latin America. Lower-skilled Cubans are moving to the cities, primarily Havana, to survive, but there are few jobs. “North Havana” – the locals’ term for Miami and South Florida. “It’s complicated” was the usual first response to our educational group’s tougher questions of the many Cubans we met – including a former Foreign Minister, young artists, entrepreneurs, and academics. Detailed and surprisingly candid answers then often followed. Creativity and resiliency abound within the populace – notwithstanding governance that has morphed from corrupt dysfunction to atrophy. One example is social media participation. With often unavailable electric power, limited bandwidth, and large-scale official surveillance, Cuban entrepreneurs and activists use a combination of technological innovation and old-school ingenuity (e.g., bicycle messengers regularly and systematically distributing hard drives) to stay socially, politically, and commercially current and engaged.

I have been thinking about Jimmy Carter this week and his contributions to the fight against corruption during his Presidency. These contributions were both domestic and international. Jimmy Carter signed the Foreign Corrupt Practices Act into law on December 19, 1977. The early years of FCPA enforcement, which were active years, were on his watch. Carter also emphasized ethics in government, pushing for greater transparency and accountability both of government and official conduct and government dealings with the private sector. This included passage of the Ethics in Government Act of 1978. Many of these reforms have since been reflected in international treaties such as the United Nations Convention Against Corruption and best practices from a preventive point of view. The Coalition recognized him with its highest award, the Integrity Award, in 2015, for his work both during his Presidency and subsequently through the Carter Center. At the time, we recognized that much remained to be done. In 2021, we published a set of recommendations for the new administration. Four years later, those recommendations stand. There is still much to be done. Lucinda Low

The disproportionate impact of state-owned enterprises (SOEs) in the global economy is under-appreciated. In 2023, the OECD estimated that 126 of the largest 500 global corporations?(by revenue) were SOEs. And yet, among the 'SOEs and Integrity Challenges' topics covered today by Nicola Bonucci and Alison McMeekin in the Coalition for Integrity’s Corporate Forum: standards, transparency, and country policies are often lacking; conflicts of interest abound – as states function simultaneously as owners, regulators, and policy-makers; and a clearly uneven and high bribery risk playing field results in many countries. Those companies re-shoring from China, and disengaging from SOEs there, find new SOE challenges as they enter India, Indonesia, Malayasia, Mexico, Thailand, and Vietnam. Thanks to Nicola and Alison for a highly informative session. #SOEs, #Integrity, #antibribery

DETAILS ON C4I CORPORATE FORUM – “INTEGRITY CHALLENGES AND STATE-OWNED ENTERPRISES” - TUESDAY 12/17 – 11 AM EST Participants: Nicola Bonucci – former OECD General Counsel and Avocat-Professeur Associé/Attorney-Associate Professor; Alison McMeekin, former OECD Team Lead, Integrity & Sustainability in State companies, Financial & Enterprise Affairs Directorate; and Worth MacMurray, C4I CEO. SOEs are in the news. The recent $122 million McKinsey Africa settlement involved a state-owned utility. As US companies reshore from China to India, Indonesia, Malaysia, Mexico, Thailand, and Vietnam, and/or consider Mexican companies as local partners for the ’26 FIFA World Cup, SOE interaction and issues may arise. Join us to explore the challenges of working with and competing against SOEs. Teams link: https://lnkd.in/gvfe9PU7 Meeting ID: 210 943 054 628 Passcode: AX7bn3Yp