Anti-corruption has become a major global initiative, as evidenced by efforts of organizations such as the World Trade Organization (WTO), European Union, Organization of American States, Association of Southeast Asian Nations, Caribbean Community, and the African Union, among others, to require their members to address it. That all said, it is naive to expect that legislators, regulators, international trade organizations and other parties can eradicate customs and behavior that has evolved over many centuries. This issue of The Bulletin will discuss the management of corruption risk and uses the FCPA as a framework for this discussion.