Here is the part I liked best about Dach's piece, while the tone was set by Chief Executive Officer (CEO) Mike Duke "ultimately, the challenge isn't the CEO's job, or one person's job; it is everyone's job." Last December Matt Ellis wrote a great piece on his blog site, FCPAméricas, entitled " Wal-Mart, Go Big on FCPA Compliance ", where he challenged the company to innovate in compliance "by playing to its strengths." He cited examples of work in the company's supply chain; its opportunities to "educate foreign audiences on [anti-corruption] compliance" through teaching persons in the communities where it has locations on "how to identify and avoid risks of petty corruption." Ellis ended his piece with the following, "Wal-Mart has the spotlight. Time will tell if it chooses to use it." I think that Dach's challenge to create a better company, coupled with Ellis' specific challenge for Wal-Mart to go big for compliance, present an excellent juxtaposition to the whining and belly-aching of the ICC.