Coughing Up Executives or Rolling the Dice?: Individual Accountability for Corporate Corruption

Professor of Corporate Compliance and Enforcement, Erasmus University Rotterdam, the Netherlands; formerly, Visiting Fellow, University of California, Berkeley School of Law; and a Senior Associate at De Brauw Blackstone Westbroek ( This Article reflects my personal views. I am thankful to Susan Rose-Ackerman, Bruce Ackerman, and the participants of the conference, The Reform of the Regulatory State: Resilience in Times of Crisis, Maastricht University, the Netherlands (January 2016), for useful comments. I am also thankful to Ingeborg Braam for her invaluable assistance.