Foreign Corrupt Practices

If you are or ever have been in the financial services industry, you will recognize those uplifting training courses you have to take from time to time, mostly to enable your employer to document its ass covering efforts.

Usually the course offerings are online and they feature pensive looking, multicultural individuals facing ethical dilemmas.

For example, it might be important to document the training of employees in the pitfalls of foreign corrupt practices.

No country wishes to be left behind in its steadfast opposition to bribing the officials of other countries, hence the laws are quite broad in defining concepts like bribery (everything), who might be bribed (everyone), who might be guilty (again, everyone), who can prosecute you (yet again, everyone no matter where you happen to live,  the United States, England or Singapore can come after you).

Amid the admonitions to “consult your legal department if you’re in doubt,” there are helpful tips for avoiding draconian penalties and ruinous personal liability. Finally, the person taking the course is asked a bunch of questions that he must eventually get right although repeated tries are on offer. (Tip: if the sound happened to go off and you didn’t hear some of the course, simply choose the most overreaching answer as it is likely to be correct.)

So, let’s say hypothetically that I had recent exposure to an offering of this nature and let’s say, again hypothetically, that I am only tangentially involved in the industry and might only be exposed to such pedagogy to maintain a largely dormant license.

Under such circumstances, the mind might just wander. Where might it go?

Only the most careful readers will have observed the words “bribing the officials of other countries” above. There appears to be no proscription against bribing the officials of one’s own country. Judging from the examples, it is pretty clear that the entire campaign finance system in the United States would violate the lessons taught in this course.

Since it is abundantly clear that no domestic agency will do anything about that, perhaps we can rely on the good people of England or Singapore to come here and apply the long arm of their laws to us.

Campaign professionals might wish to be on alert as their livelihoods are now threatened.

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