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Friday Roundup


DOJ’s year in review, ripple, scrutiny alerts and updates, simply false, and amusing. It’s all here in the Friday roundup.

DOJ’s Year In Review

The DOJ Fraud Section recently released its year in review. According to the document, “the FCPA Unit has 32 prosecutors.” When reviewing the statistics in the document keep in mind that the FCPA Unit “investigates and prosecutes cases under the FCPA and related statutes.” In other words, the statistics include non-FCPA matters such as when the DOJ charges or prosecutes alleged “foreign officials” for money laundering and related offenses.

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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.

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Do Corruption Rankings Actually Tell You Things You Don’t Already Know?

question marks2

For many years, Transparency International’s Corruption Perception Index (CPI) was the only game in town. (See here for why compliance professionals should take the CPI with a grain of salt).

But with each passing year it seems, there are other attempts to measure corruption and a sort of corruption index competition has developed. In other words, my corruption index is better than your corruption index and here are the reasons why.

For instance, this recent FCPA Blog post is titled “Not All Corruption Indexes Are Created Equal” and like much of what appears on the FCPA Blog the post is written by a person pushing their own organization’s product or service offering.

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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:

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