Top Menu

FCPA Flash Podcast – A Conversation With Machua Millett Regarding FCPA Insurance

Podcast Logo

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Machua Millett (Chief Innovation Officer, FINPRO US Marsh) regarding FCPA insurance. In 2012, FCPA Professor published this Q&A with Millett regarding the topic and in the podcast Millett provides an update on the relevant issues.

Continue Reading

Friday Roundup


Funny, scrutiny alerts and updates, and for the reading stack. It’s all here in the Friday roundup.


According to the FCPA Blog, there is “nothing too complicated or expensive” about FCPA compliance.

That’s funny because on a daily basis FCPA Blog content is flanked by approximately 20 blinking and flashing ads from FCPA Inc. participants.

Continue Reading

Flip-Flop On The Merits Of Voluntary Disclosure


Based on conversations I’ve had with several Foreign Corrupt Practices Act practitioners (those in law firms and those in companies), one common frustration with FCPA enforcement is the extent to which government enforcement attorneys say one thing while with the government and then say another thing  (often contradictory) when they leave the government.

The below flip-flop example concerning the merits of voluntary disclosure is not the only example (see here for a similar prior post), yet represents the latest example.

Continue Reading

FCPA Inc. Desperately Needs Some Basic Standards


In 2010 I coined the term “FCPA Inc.” as shorthand term used to describe a vibrant, niche industry consisting of numerous market participants and not just lawyers. Regardless of what you think of the term, FCPA Inc. has become part of the FCPA lexicon and it is undisputed that FCPA Inc. is a multi-billion dollar industry.

Most mature niche industries have basic standards (a common language if you will) concerning basic issues relevant to the industry. However, FCPA Inc. has none and it resembles the wild west in many instances.

Consider the following basic question: how many corporate enforcement actions were there last year and how much money did the U.S. government collect in those enforcement actions? As highlighted below, certain FCPA Inc. participants have answered this question four different ways.

Continue Reading

Is This Appropriate?

© ClassicStock / Masterfile
Model Release: Yes
Property Release: No

Gibson Dunn is generally viewed as having a top tier Foreign Corrupt Practices Act practice.

The firm’s Year-End FCPA Update is always a quality read including this year’s version.

Yet, highlighted below is a paragraph from the Update that caught my eye and I ask: seriously – is this appropriate?

Early in the 36-page document is the following paragraph:

Continue Reading

Powered by WordPress. Designed by WooThemes