FCPA Professor enjoys a diverse group of readers including law students and young associates interested in careers that focus on the Foreign Corrupt Practices Act.
To these readers and others, meet Laura Greig, a 2010 graduate of the University of Texas School of Law and a current associate in the Houston office of King & Spalding.
In the below Q&A, Greig describes her FCPA experiences to date and provides advice to those interested in FCPA careers.
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What was your first FCPA-related assignment?
I joined King & Spalding as a summer associate hoping to become involved in the FCPA practice, and I was lucky enough to get started right away. My first FCPA assignment that summer involved a survey of enforcement actions related to financial service institutions, with a focus on African jurisdictions. It was a great introduction to King & Spalding’s FCPA practice, and I was able to rejoin the team when I started as a full-time associate.
What countries have you visited doing FCPA work?
China, Bahrain, Mexico, Saudi Arabia, and the United Arab Emirates.
Of those countries, what has been your most memorable experience?
There have been many interesting destinations and experiences, from packing complications (try packing binders for 25 interviews into your carry-on to keep them locked and secure), to wardrobe issues (as a woman measuring almost six feet tall, it was not easy to find a properly-fitting abaya). As most people reading can understand, my clients probably would not appreciate sharing my most interesting in-country experiences, given their context, but there have been plenty of other memorable moments. I’ve always loved to travel, and even if 20 of 24 hours in every day abroad are focused on the task at hand, every trip has some experience that satisfies my personal travel bug. Things that seem simple stick with me for a long time, like watching a stunning sunrise over the Persian Gulf and being able to truly appreciate and understand where I was in the world. Of course, I was only awake to see that sunrise due to travel delay, back-to-back red-eye flights, and resulting food poisoning from consecutive airline dinners—but it was memorable nonetheless.
As you learned more about the FCPA, what surprised you the most?
I’d have to say that the most surprising aspect about the FCPA is the breadth of its reach. The growing global marketplace, paired with the government’s expansive application of the statute, makes it seem as though almost any entity or individual could face FCPA scrutiny. It’s interesting to track the development of the enforcement climate as aspects of the statute evolve (almost unchecked), like the limits of FCPA jurisdiction or who is considered a “foreign official.”
If you could change one thing about the FCPA or FCPA enforcement, what would it be?
I would make FCPA enforcement more transparent. As it stands, there is very little case precedent, which leaves practitioners to rely on their own enforcement experience and other corporate settlements that were arrived at behind closed doors. I think it would help to level the playing field if everyone could understand more clearly how often and why the enforcement authorities choose not to bring cases; how the government decides on a particular type of settlement (e.g., NPA versus DPA); and what specific facts of a case were considered and given weight in determining a particular outcome. With more transparency, companies could have clear insight into how they should proceed, both from a proactive compliance standpoint and when they investigate potential FCPA issues.
What advice do you have to students or young associates interested in having an FCPA practice?
When selecting a law firm, make sure it has a dedicated FCPA practice with a deep bench of attorneys specializing in the area. This will not only increase your likelihood of getting to work on FCPA matters, but will provide you with opportunities for great mentoring and the chance to work with experts in the space. I was lucky enough to join a firm that has a substantial number of associates and partners whose time is predominantly, if not wholly, devoted to FCPA work, and from whom I have learned a tremendous amount. It’s also of the utmost importance to stay on top of developments in the anti-corruption arena—not just related to the FCPA. Anti-corruption issues are in the spotlight on a global level, and it is a quickly developing area with evolving legal issues. Lastly, to be an effective FCPA associate working on investigations or compliance issues, you must understand both sides of the coin—how to address the unique issues that arise in connection with an FCPA investigation, and also the anti-corruption compliance best practices that should be employed to help prevent and mitigate anti-corruption risks.
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