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Friday Roundup


Scrutiny alert, novice FCPA commentary matters, additional charges, survey says, across the pond, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alert

Some companies disclose Foreign Corrupt Practices Act very early and then update the disclosure for years. Other companies have different disclosure practices. Global asset management firm Legg Mason Inc. (a company that has not previously disclosed FCPA scrutiny) recently disclosed:

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Why Does The Media Have Such Difficulty Accurately Describing The FCPA?

Mid adult teacher sitting behind desk in classroom

Call me old-fashioned, but when paid journalists write about the Foreign Corrupt Practices Act there is a duty to get things right. A duty to conduct basic research and verify or confirm the truth of the matter asserted.

FCPA Professor has chronicled for years numerous “not so finest FCPA moments” of the media (see here,¬†here, here, here and here) and the latest is courtesy of this Newsweek article.

If the definition of fake news includes published material with objectively false information, then portions of the Newsweek article is fake news. This post is particularly timely following DOJ Compliance Counsel Hui Chen recently calling out certain compliance commentary for its lack of precision and intellectual rigor and her call for a #precisionmatters hashtag on social media.

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Wal-Mart’s FCPA Scrutiny DID NOT Begin With The April 2012 NY Times Article


If you follow media reporting (and certain FCPA commentators) you probably heard the narrative before: Wal-Mart’s Foreign Corrupt Practices Act began with the April 2012 New York Times article.

However, this is false.

Set forth below is the chronology of Wal-Mart’s FCPA scrutiny – as even reported by the New York Times – and based on other information in the public domain.

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About That New Yorker Trump Organization Azerbaijan Story

kidding me

For years FCPA Professor has highlighted numerous examples of – shall I say – not the media’s finest moments when it comes to Foreign Corrupt Practices Act reporting. (See here, here, here and here).

Although FCPA Professor has highlighted several examples, Adam Davidson’s recent New Yorker article about the Trump Organization in Azerbaijan (see here for the original post highlighting several concerns about the article) and his subsequent comments and writing about the matter are in a league of their own.

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