Honor and the FCPA

This is a compelling question: FCPA Professor on Trust in the Corporation

Can a culture of trust — of honor — work better as a corporation’s FCPA defense than a labyrinth of rules?  This is not merely a “tone at the top” kind of question.  Rather, it requires a commonly-shared landscape of what is honorable conduct; a handful of commonly-shared principles of comportment; everyone’s understanding that this system works to the benefit of all; and a single-sanction intolerance for whatever wanders outside that ethical landscape.

Even if the honor-culture is more effective than checking-off-the-boxes in your department’s compliance template, how does a company in an FCPA case defend the honor-culture to investigating Government agents and lawyers?  Won’t they desire to see how many boxes were (or were not) checked?