This is certainly not the first time these pages have addressed this topic and of all the topics periodically discussed on these pages, this topic has received some of the most positive feedback.
For profit companies that host FCPA conferences are entitled to run their business as they see fit. However, when for profit companies use enforcement officials at the DOJ and SEC like commodities that are then marketed and sold to the public, this is where the line needs to be drawn.
It’s a disgraceful practice and it needs to stop. Moreover public officials need to stop allowing themselves to be used as pawns by for profit companies.
A common marketing device the conference companies use in hopes of driving attendance to their paid events is by touting the public officials who will speak at the event. With the current COVID-19 environment, large in-person events are not possible. Yet as highlighted below, a for profit conference firm is now marketing “virtual” access to our public officials to drive virtual attendance to their paid event.
As highlighted here, a for profit conference firm is pitching a “virtual government town hall” with Daniel Kahn (Senior Deputy Chief, Fraud Section, DOJ) and Steven Peikin (Co-Director, Division of Enforcement, SEC). As stated by the conference firm:
“As we navigate these unprecedented times together, ACI is pleased to offer our esteemed delegates an opportunity to virtually connect with key officials of the DOJ and SEC – to discuss their respective approach to ensuring continued FCPA compliance and enforcement. Submit your questions prior to or live throughout the session. All questions will be pre-screened and shared with the faculty on a strictly anonymous basis.”
However, the “virtual government town hall” is not free. To hear what your public officials have to say about enforcement of an important law impacting all business organizations doing business in the global marketplace and to have “an opportunity to virtually connect with key officials of the DOJ and SEC” you have to register for the event and that will cost you $2,095.
It is a bit ironic that these conferences focus on FCPA topics, yet the problematic conduct highlighted above occupies the same general space, is marketed in plain view, and has corporate sponsors and advisory board members well versed in FCPA issues.
The selling and marketing of FCPA enforcement officials by private companies is a disgraceful practice that needs to stop. FCPA enforcement officials are public officials, not a commodity that a for-profit company should be allowed to sell.
Moreover, public officials need to stop allowing themselves to be used as pawns by for profit companies.
These are serious issues that deserve more attention and corrective action.