Recently, the US Department of Justice (DoJ) and the Securities and Exchange Commission (SEC) have increased enforcement of the Foreign Corrupt Practices Act (FCPA) targeting violators in different industries, including Direct Selling. In a nutshell, the Act prohibits the offering or payment of “anything of value” to a “foreign official” for the purpose of obtaining or retaining business. This paper examines the potential for mitigating FCPA-related risks in the Direct Selling industry in Emerging Markets (EMs) by adopting an IT-enabled, integrated, proactive model of corruption risk management, which recognizes the anti-corruption imperative as an integral part of company mission and strategy.