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Friday Roundup

Just don’t call it bribery, help wanted at the DOJ, and SEC names a new enforcement director. It’s all here in the Friday roundup.

Just Don’t Call It Bribery

Even though this past January’s presidential inauguration was substantially scaled down from prior inaugurations because of COVID, according to this article [1] President Biden’s inaugural committee raised $61.8 million for the televised virtual event.

Among the companies that gave $1 million were Bank of America Corp., Lockheed Martin Corp., Comcast Corp., Levantine Entertainment, Masimo Corp., Uber Technologies, AT&T Inc., Boeing Co., Pfizer Inc., and Qualcomm Inc.

As noted in the article, “top donors were offered perks including virtual events with Mr. Biden, Vice President Kamala Harris and their spouses as well as sessions with top Biden advisors.”

FCPA enforcement agencies bring enforcement actions which contain allegations about golf in the morning and beer drinking in the evening, tickets to sporting events, and other nominal things of value provided to alleged foreign officials such as scuba diving lessons.

But $1 million donations to a specific government official’s inaugural committee in exchange for access? Just don’t call that bribery.

Why are business interactions with “foreign officials” subject to different standards than business interactions with U.S. officials?

As you contemplate this question, just remember the following statement from a DOJ enforcement attorney that “we in the United States are in a unique position to spread the gospel of anti-corruption.”

See here [2] for a similar post in connection with President Trump’s inauguration and here [3] for President Obama’s inauguration.

Help Wanted

The DOJ recently posted this job opening [4] for an attorney position in its FCPA Unit. The position contains the following job descriptions:


It is interesting that the DOJ acknowledges in its job description that FCPA enforcement may involve “complicated questions of law.” Yet another blow to those [6] who (inaccurately) maintain that the FCPA is clear in all cases.

At the SEC

The SEC recently announced [7] that Alex Oh has been appointed Director of the Division of Enforcement. As stated in the release:

“Oh was most recently a partner at Paul, Weiss, Rifkind, Wharton & Garrison LLP and co-chair of the law firm’s Anti-Corruption & FCPA Practice Group. She was previously an Assistant U.S. Attorney in the Criminal Division of the U.S. Attorney’s Office for the Southern District of New York, where she was a member of the Securities & Commodities Fraud Task Force and the Major Crimes Unit.”

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Connect [8]