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The Political Contributions Of Various FCPA Commentators

Political fund raising / contributions. A skimmer hat full of bundles of $100 bills and a hat on a money bag on a white background

FCPA commentators often write about the importance of transparency.

The question arises, when FCPA commentators write about topics political in nature including statements about specific political actors, should the commentator disclose their political contributions so that readers can better assess the credibility and objectivity of what the commentator is saying?

This post highlights the publicly available political contributions of various FCPA commentators.

For the record, I’ve never made a political contribution in my life.

Before highlighting the publicly available political contributions of various FCPA commentators, let me explain the origins of this post.

Previous posts here and here highlighted the March New Yorker article published by Adam Davidson concerning the Trump Organization’s business dealings in Azerbaijan. The article, in part, concerned the Foreign Corrupt Practices Act and the previous posts highlighted how the article was in a league of its own against the backdrop of other not so fine FCPA media moments.  (See herehereherehere and here).

Recently, I listened to this “Bribe, Swindle or Steal” podcast (recently launched by Alexandra Wrage of Trace International) in which Davidson was once again gushing about the article. What struck me about the podcast was how Davidson seemed to be thanking Wrage for her assistance in connection with the article. This prompted me to re-read the March article which then prompted me to research public information concerning political contributions by certain FCPA commentators cited in the article. For instance in the article, Davidson used various comments by Wrage and Thomas Fox in support of his supposed narrative that the Trump Organization, and Donald Trump himself, may have violated the FCPA.

Surely, a journalist who spends 3.5 months on one article (as Davidson said he did), would research easily-available public sources to see if the FCPA experts cited in support of the article’s narrative had, for instance, actively supported Trump’s opponent in the recent election?

Doing so only takes a minute or so on the Federal Election Commission’s website and it would seem, given the nature of the New Yorker article, that readers might be interested in the political contributions of various experts cited in the article.

The FEC website contains the following recent information about Wrage.

The FEC website contains the following information about Fox.

I then became interested in the political contributions of other FCPA commentators. For instance, Matthew Stephenson has been very vocal about many things Trump on his Global Anti-Corruption Blog (see here for just one post).

The FEC website contains the following information about Stephenson.

The civic engagement of the above group of FCPA commentators is to be applauded.

Yet, the question arises, when FCPA commentators write about topics political in nature including statements about specific political actors, should the commentator disclose their political contributions so that readers can better assess the credibility and objectivity of what the commentator is saying?

It is hoped that this post contributes to more transparency in the FCPA space.

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