Bribery is a serious and under-appreciated risk for U.S. companies doing business overseas.

Anti-bribery compliance programs significantly reduce bribery risks and consequences. Programs tailored to a business’s unique facts and circumstances can help identify and mitigate bribery possibilities.

Customary anti-bribery techniques focus on high-risk activities, personnel training and applying appropriate controls.

An effective anti-bribery compliance program may result in law enforcement deciding not to pursue charges if there is a bribery event – because the event is seen as non-systemic, and because the company has made proactive efforts to do the right thing.
Meet the Expert

About Worth

  • Works with global companies to prepare for ISO 37001 independent 3rd party audits
  • Expertise in advising C-Suite, Board of Directors and operational personnel on regulatory compliance and supplier requirements, and related investigations
  • Public and private company General Counsel and Chief Compliance Officer experience with a wide range of corporate business, strategic and legal matters, including:  M&A, SEC, IP licensing and protection, equity and debt financing, commercial dispute resolution, bid protests, government contracts, software revenue recognition, employment and strategic growth initiatives
  • Member of the U.S. Technical Advisory Group for the ISO 37001 international standard for anti-bribery management systems
  • Working territories - US, Europe, Latin America, the Caribbean, Asia/Pacific, and Africa 


Principal • Governance & Compliance Initiatives, LLC
Jun, 2016 — Present
  • Provide ISO 37001 Anti-bribery management systems advice and counsel
Senior Vice President • GAN Integrity Inc.
Jun, 2015 — May, 2016
  • Led corporate thought leadership development and industry relationship building activities for US sub of Danish SaaS-based compliance platform provider
  • Product design team member
  • Compliance subject matter expert
Director • PwC
Jun, 2010 — May, 2015
  • Specialized in delivering holistic and effective anti-corruption and cyber governance oversight compliance assessments and programs for private (companies of all sizes, public and private) and public sector (Haiti, Kurdistan) clients.  Corporate intelligence, strategic threat management and governance/risk/compliance (GRC) matters were typically involved.
  • Member of the firm's Anti-Corruption, Corporate Intelligence and Threat Management groups, and on the editorial board of PwC's global publication: "Resilience: Winning with Risk" 
Director • Grant Thornton
2009 — 2010
  • Member of Advisory practice's risk management group.
  • Represented firm on World Bank Collective Action Task Force.
  • Helped create and lead group that developed proactive methodologies and tools for business in emerging markets to fight corruption through collective action - 
Independent Consultant • Global Governance, Risk & Compliance (GRC)
2003 — 2009
  • Provided anti-corruption services through leading projects in US, Germany, Pakistan, Ghana and Argentina.
  • Approved by SEC and US Army Office of Suspension and Debarment as compliance officer to implement corporate compliance programs in troubled company situations.
  • Experience with multi-national conglomerates, technology, electronics, oil and gas and government contracts sectors - and with multi-lateral financial aid institutions.
General Counsel • Network Access Solutions
2002 — 2003
  • Managed legal affairs of publicly-listed telecommunications company
General Counsel • Landmark Systems
2000 — 2002
  • Managed legal affairs and European mergers & acquisitions for global public software company
General Counsel • INTERSOLV
1998 — 2000
  • Managed legal affairs and conducted U.K. and U.S. mergers & acquisitions for global public software company. Recipient of numerous project leadership awards.
General Counsel • GTSI
1996 — 1998
  • Managed legal affairs for government market IT reseller. Successfully defended and settled major customer litigation. Recipient of numerous project leadership and management awards.


Georgetown University
JD, 1980
Princeton University
AB, Woodrow Wison School of Public and International Affairs, 1977

Licenses & Certifications

PECB Certified ISO 37001 Lead Implementer 


  • Served on ANSI-accredited U.S. Technical Advisory Group for ISO 37001 (Anti-bribery management systems)
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