The “Bait”

On February 10, 2025, President Trump signed an Executive Order titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security”.  A Wall Street Journal article reporting on the action characterized it as follows:

President Trump has put the brakes on a law that forbids U.S. companies from bribing foreign officials to win business.

The Executive Order presents the ability of American businesses to pay bribes as a matter of national security

American national security depends in substantial part on the United States and its companies gaining strategic business advantages whether in critical minerals, deep-water ports, or other key infrastructure or assets. . .. But overexpansive and unpredictable FCPA enforcement against American citizens and businesses — by our own Government — for routine business practices in other nations not only wastes limited prosecutorial resources that could be dedicated to preserving American freedoms, but actively harms American economic competitiveness and, therefore, national security.

For faithful leaders of organizations operating internationally, the bait has been placed and the trap has been set. Nicky Gumbel has observed about sin:

All sin involves a kind of deception. It often involves the disguising of evil as good.

Proverbs 5:1-8 uses much more colorful language to make the same point.

My son, be attentive to my wisdom; incline your ear to my understanding, that you may keep discretion, and your lips may guard knowledge. For the lips of a forbidden woman drip honey, and her speech is smoother than oil, but in the end she is bitter as wormwood, sharp as a two-edged sword. Her feet go down to death; her steps follow the path to Sheol; she does not ponder the path of life; her ways wander, and she does not know it. And now, O sons, listen to me, and do not depart from the words of my mouth. Keep your way far from her, and do not go near the door of her house.

We believe faithful leaders seeking to lead with faithful integrity in alignment with Biblical beliefs, principles, and priorities must heed the advice of Proverbs and resist the “honey”.  An organization pursuing faithful integrity through business a better way toward Biblical flourishing must not take the bribery bait, even if bribery becomes “legal”, is unlikely to be pursued as “illegal”, or is portrayed as “good for America”.

What is “Bribery”

The Merriam Webster Dictionary defines “bribe” as “to influence the judgment or conduct of (someone) with or as if with offers of money or favor.”  Our friend Dr. Skip Moen defines it as “a gift that carries selfish intention“.  “Bribery” comes in many forms, some of which is legal and some of which is illegal.  Some of it is even done in the name of noble purposes. We believe practices undertaken to try to influence the “judgment or conduct” of others “with offers of money or favor” go way beyond what we usually think of as “bribery”.

For example, under the U.S. Foreign Corrupt Practices Act (“U.S. FCPA”) that is the subject of President Trump’s order, it is unlawful for a U.S. person or company to offer, pay, or promise to pay money or anything of value to any foreign official for the purpose of obtaining or retaining business, but it is not unlawful to make any facilitating or expediting payment to a foreign official, political party, or party official the purpose of which is to expedite or to secure the performance of a routine governmental action.  In essence, it isn’t illegal to pay a bribe to get a government official to do what they are supposed to do.

In post #156 (Integrity Idea 019: Banish Bribery), we suggested that aligning an organization’s vision, values and culture with Biblical beliefs, principles and priorities requires a more expansive concept of “bribery”.  We believe faithful leaders pursuing faithful integrity must also view “bribery” as including activities such as entertaining or the offer of “favor” or gifts for the purpose of obtaining or retaining business, lobbying for political action or even securing donations.

Of course, not all entertaining, favor or gifts are made with “selfish intention” or for the purpose of “influencing judgment or conduct”.  Ultimately, it is about intention and “heart” and requires prayerfully reflecting on the real WHY behind giving or accepting things like payments, favors, entertaining and gifts.

Biblical Basis for “Don’t Take the Bribery Bait”

The Bible is full of passages that warn against bribery.  Here are just a few:

• And you shall take no bribe, for a bribe blinds the clear-sighted and subverts the cause of those who are in the right. (Exodus 23:8)

• Whoever is greedy for unjust gain troubles his own household, but he who hates bribes will live. (Proverbs 15:27)

• The wicked accepts a bribe in secret to pervert the ways of justice. (Proverbs 17:23)

• Surely oppression drives the wise into madness, and a bribe corrupts the heart. (Ecclesiastes 7:7)

• You shall not pervert justice. You shall not show partiality, and you shall not accept a bribe, for a bribe blinds the eyes of the wise and subverts the cause of the righteous. (Deuteronomy 16:19)

“Bribery” is clearly inconsistent with Biblical beliefs, principles and priorities, which makes it inconsistent with the pursuit of faithful integrity through business a better way.   Paying or accepting a bribe not only causes the party receiving or offering it to “stumble” (Romans 14:13)–it also validates a worldly culture of bribery, corruption and manipulation.  Looking to one of our favorite cultural commentators, Seth Godin observes:

The posture of, “cheat if you can,” is the belief in the ends at any cost. It degrades the system, because if everyone cheats, then there is no system left. . . .  Sophisticated competitors, the ones who really want to win, understand that cheating destroys the very thing they set out to do. Because once cheating is normalized, the winner is the person who had the guts to cheat the most and destroy the system, not the one who deserved to win. . . . Our systems persist only when peers in the community step up and insist that the cheater stop.

The Challenge of Not Taking the “Bait”

In many countries corruption is rampant.  In this type of environment, not taking the bait of bribery even at the most basic level of illegal payments to government officials can be a tremendous challenge.

In a jurisdiction where corruption is illegal but common, many businesses operating according to worldly principles accept and engage in illegal bribery as part of business as usual.  As suggested by President’s Trump’s Executive Order, those who don’t pay bribes can see themselves at a competitive disadvantage.

The Executive Order makes the bait even sweeter–harder to resist and easier to rationalize–by giving bribery the noble purpose of U.S. national security!  Such a noble purpose could mistakenly be seen as muddying an important distinction we have made between business as usual and business a better way–the distinction between a “Can We” and a “Should We” cultures.

As we have described in earlier posts, a “Can We” culture is a characteristic of business as usual.  It is an organizational culture in which ends justify means and ethics or the law are seen as the only boundaries (or even obstacles) in the pursuit of the organization’s purpose.

A “Can We” culture is, in many ways, the product of Profit as Purpose fueled by Scarcity and Self-Interest dynamics.  As we have noted in an earlier blog, Profit as Purpose does not support enduring values because it has no moral, ethical or Biblical foundation.  Although “values” may have such a foundation, values in service to Profit as Purpose become a “means” to the “end” and the “means” will always adjust to fit the “end” (never vice versa).

In a “Can We” culture:

• People are explicitly or implicitly rewarded for asking things like:

• “Is it illegal or does it violate any rule?”

• “Are our competitors doing it?”

• “Are we likely to get caught?”

• “Is it defensible if we are caught?”

• “Is our customer demanding it?”

• Competition (whether internal or external), a fear of losing business (both tied to the scarcity assumption), and a desire to increase business can lead to pushing (or even crossing) boundaries.

The problems of a “Can We” culture are many:

• Competition will drive behavior to the edges and beyond.

• It is unprincipled, condones risk-taking and has a short-term focus.

• It is toxic to the desire we believe is built into each human to do the right thing and glorify God and, because moral failures typically occur through EROSION rather than EXPLOSION, can even lead people to do things they never imagined possible and that they will ultimately regret.

By contrast, a “Should We” culture asks “Whether or not we CAN do it (or get away with it), SHOULD WE do it?” “Should We” can call people to a standard higher than merely man-made laws or the current societal ethics–it can call them to the Biblical standards that they were created to emulate, and it can call them to the organization’s values.

This kind of business a better way organizational culture only arises when there is a commitment by the most senior leaders:

• To lead the organization in pursuing a “WHY” that is bigger than maximizing profit and in living out a set of values that reflect and reinforce that mission.

• To lead the organization in pursuing that purpose by doing the right thing, in the right way, for the right reasons and by supporting all workers in doing the same.

• To maintain a long-term focus.

• To cultivate an intentional culture that reflects and reinforces those values and that purpose.

• To trust in God’s promises and sovereignty.

In a “Should We” culture, people ask things like:

• “Is it consistent with how we want to serve our stakeholders?”

• “Is it consistent with our values?””

• “Is it consistent with our intentional culture?”

• “Is it doing the right thing, in the right way, for the right reasons?”

• “Is it consistent with what we say we stand for and who we say we are?”

A faithful leader might be tempted by the Executive Order to entertain just a little bit of bribery, taking comfort that they would be “crossing the street in a crowd”, but that would be “Can We” thinking out of alignment with business a better way.  Just before condemning bribery in verse 8, Exodus 23:2 commands, “You shall not fall in with the many to do evil.”

Although it may seem that giving bribery a noble purpose like national security blurs the line between “Can We” and “Should We”, we believe it is merely the “disguising of evil as good” in Nicky Gumbel’s observation on sin.

A Faithful Approach to the Temptation of Bribery

We have said that a goal of an organization pursuing faithful integrity through business a better way is that people will come to instinctually do the right thing, in the right way, for the right reasons.  A key to understanding faithful integrity is recognizing that “doing right” needs an object–by whom are we to “do right”.

Business as usual toward Profit as Purpose says an organization needs to “do right” by its owners above all other objects. Business a better way toward Biblical flourishing requires the organization to “do right” by God above all other objects, because God is its ultimate owner.

“Doing right” by an owner means pursuing the will of the owner, which in case of the business as usual is Profit as Purpose.  Pursuing the will of God through business a better way requires acting in alignment with Biblical beliefs, principles and priorities.  The will of God does not include bribery, notwithstanding any noble sounding purposes assigned to it.

Leading with faithful integrity through business a better way toward Biblical flourishing requires a faithful leader to choose obedience over outcome, trusting God’s promises and sovereignty enough to surrender control of difficult circumstances to God’s will, regardless of the cost.  Bribery is an outcome-driven effort to take control of difficult circumstances through human manipulation that is devoid of trust in God and contrary to Biblical beliefs, principles and priorities.

Dr. Skip Moen has noted one place in which the Bible seems to paint bribery in a positive light.

A bribe is like a magic stone in the eyes of the one who gives it; wherever he turns he prospers. (Proverbs 17:8)

He offers an interesting insight into Solomon’s statement.

What Solomon observes is that the person who uses a bribe does so because he is convinced that the bribe will bring about his desire. It is a belief in control. If I can’t get what I want through legitimate means, then I will get it through illegitimate means. . . .  Solomon’s insight is simple. If we let God take care of the circumstances of life and we faithfully manage the vertical relationship with Him, the need to control others disappears. When the need to manage my circumstances is given over to God’s hand, bribes are seen for what they truly are – attempts to act with sovereignty over others. You don’t have to hand over an envelope full of money to believe in bribes. All you have to do is manipulate life around you for your own ends. . . .  Bribes come in all shapes and sizes but not a single one recognizes the God Who is.

In many situations, refusing to take the bait of bribery, even if the government says it will “look the other way”, is counter-cultural, and counter-cultural actions by a faithful leader require courage and trust.  A faithful leader of an organization committed to leading faithfully through business a better way will face challenges that require the utmost trust in God’s sovereignty and trust in God’s promises.

Here are four real-life examples of challenges faced by faithful leaders operating in jurisdictions in which corruption and bribery is illegal but common.

• A faithful lawyer shared that he won a court case for his client, but the court will not issue the decree without payment of a bribe.  He has been faithfully resisting for nearly a year, but his client is anxious for resolution and the lawyer fears that his faithful approach may be detrimental to his ability to earn a living if prospective clients learn he will not “play the game”.

• A faithful businessman refused to pay bribes in order to service equipment his company had installed to help small villages, which ultimately led to the demise of his business and division within his family.

• A faithful leader of a startup was bringing some equipment into the country and was faced with the following choice at customs: pay several thousand dollars in cash and receive a receipt for half that amount or pay a duty of triple that amount (he chose to pay the triple).

• A faithful leader of a faith-based NGO established to train local entrepreneurs in faithful business practices (including not to engage in bribery) was faced with a demand for a bribe in order to register the NGO. She ignored the counsel of friends to “just pay it and start doing good” and refused to pay the bribe (and the registration was miraculously put through).

Just as President Trump’s Executive Order sweetens the taste of bribery by giving it the noble purpose of national security, each of these faithful leaders could have taken the bait of evil being disguised for good.

• The faithful lawyer could have seen the bribe as simply facilitating the “justice” of his client’s victory and helping the lawyer stay in business to feed this family and help others.

• The faithful businessman could have seen the bribe as a small price to pay to permit villagers to continue to benefit from the equipment he installed.

• The faithful entrepreneur could have seen the bribe as good stewardship–preserving capital to permit his startup to start operating, create jobs and begin producing a product that helped people.

• The faithful NGO leader could have seen the bribe as what is required for the greater good of getting her NGO up and running to do the important work of helping local entrepreneurs follow faithful business practices.

By giving bribery a “wink” and a noble “Should We” rationalization, President Trump’s Executive Order may entice business as usual leaders pursuing Profit as Purpose to embrace one of the most unprincipled “Can We” approaches–engaging in unlawful behavior because it is unlikely to get discovered or punished.

Leading with faithful integrity through business a better way toward Biblical flourishing demands much more.  It requires recognizing the heart of bribery, turning away no matter the cost, and trusting God. Looking again to the writing of Dr. Skip Moen:

Faith is my active attitude of total reliance on God’s absolute trustworthiness. . .. If faith is the action of trusting Him, then I either act or I don’t act.  I either trust Him, or I try my own way.  There is no half-full measure here.

PERSONAL NOTE (from PM):  Two notes.  First, this post is meant as guidance for faithful leaders and not as criticism of the Executive Order or its national security rationale. The legality of behavior is merely one data point for a business a better way “Should We” approach.  Prayerful discernment of what is required for alignment with, and obedience to, Biblical beliefs, principles and priorities is most important.

Second, when I wrote post #156 (Integrity Idea 019: Banish Bribery), the issue that hit home most personally was my complicity in legal bribery.  I have been complicit by accepting “bribes” from organizations that hoped to “influence my conduct” in making donations or using their services.  As a donor, “Should I” take free trips or attend free leisure events (e.g., “President’s Retreats” or “President’s Weekends”) hosted by charities even if not prohibited by any applicable law or ethics code when I know the only purpose is to influence my giving conduct?  As a user or potential user of services, “Should I” accept invitations to sporting events or lavish affairs when I know the only purpose is to try to influence my purchasing conduct?  I don’t think I should–but the invitations are often SO dripping in honey.

ESSENCE: In the words of the Wall Street Journal, a recent Presidential Executive Order “put the brakes on a law that forbids U.S. companies from bribing foreign officials” as a matter of national security.  For faithful leaders of organizations operating internationally, the bait has been placed and the trap has been set.  An organization pursuing faithful integrity through business a better way toward Biblical flourishing must not take the bribery bait, even if bribery becomes “legal”, is unlikely to be pursued as “illegal”, or is portrayed as “good for America”.  “Bribery” is clearly inconsistent with Biblical beliefs, principles and priorities, which makes it inconsistent with the pursuit of faithful integrity through business a better way.   Paying or accepting a bribe not only causes the party receiving or offering it to “stumble”, it also validates a worldly culture of bribery, corruption and manipulation. Bribery is an outcome-driven effort to take control of difficult circumstances through human manipulation that is devoid of trust in God.  Leading with faithful integrity through business a better way toward Biblical flourishing requires a faithful leader to choose obedience over outcome, trusting God enough to surrender control of difficult circumstances to God’s will, regardless of the cost.

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Photo Credit: Original image by Maël BALLAND on Unsplash
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