There are some issues in the Foreign Corrupt Practices Act space that really should be simple.
For instance, the question “what is an FCPA enforcement action” really should be simple.
However, as highlighted in the article “A Common Language to Remedy Distorted FCPA Enforcement Statistics” various FCPA Inc. participants have adopted (for self-interested reasons perhaps) creative and haphazard counting methods regarding “what is an FCPA enforcement action.”
The end result is a muddy conversation about many FCPA enforcement issues and the creative and haphazard counting methods infect the quality and reliability of FCPA enforcement and related statistics of interest to many in the legal and business communities.
Another question that should be simple is “what is a declination.”