Many multinationals tend to see their compliance programmes from their headquarters and do not sufficiently consider that corruption risks vary enormously from jurisdiction to jurisdiction. Public procurement may be a problem in one country, but not in another. The panel discusses how the risk-based approach helps to design an effective anti-corruption compliance programme. Moderator Raphael Sore, Machado Meyer Advogados, São Paulo Speakers Isabel Carvalho, HL Consultores, São Paulo Hui Chen, Former Compliance Counsel Expert, Criminal Division, US Department of Justice, Washington DC Stefan Hoffman-Kuhnt, Pohlmann & Company, Montreal Karyn Koiffman, Baker & McKenzie, New York Joan Meyer, Baker & Mckenzie, Washington DC Volker D Popp, Daimler Mexico, Mexico City Luiz Fernando Ract Camps, International Compliance Officer, United Health Group, Miami