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.