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Is This Appropriate?

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Numerous prior posts (see here for instance) have chronicled the troubling practice of private organizations treating Foreign Corrupt Practices Act officials at the DOJ or SEC like commodities that are then marketed in ways that benefit the private organization. Related to this, is the question of why the DOJ or SEC allow their employees to be used in this way?

Trace describes itself as a “globally recognized non-profit business association dedicated to anti-bribery, compliance and good governance” whose “members include hundreds of multinational companies across all industry sectors.”

The 2022 Trace Forum was recently held and this event was “designed exclusively for TRACE member companies” and attendees could expect, among other things, to “hear from … government officials … on emerging issues affecting compliance.”

According to its website, “in order to join TRACE, a multinational company or organization must” have an anti-bribery policy in place, “sign a membership agreement” and “pay an annual membership fee.”

Given the above dynamics, is it appropriate for Trace to market public government officials and provide access to those officials only to members of its private organization who have, among other things, paid an annual membership fee to Trace? On the flip side, is it appropriate for the DOJ or SEC to allow their employees to be used in this way?

One thing is certain as indicated by the below LinkedIn screenshot. Trace was “honored to have Assistant Attorney General Kenneth Polite open the TRACE Forum … with a lively review of all that is currently underway on the anti-bribery front …”.

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