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Two Minute Warning

Boy, were we wrong. Syriana deserves our top rating of 5 Red Flags — not as a movie, but as a compliance tool. A thoughtful reader set us straight. Our sincere thanks to Daniel, whose imaginative use of Syriana we heartily endorse.

Here’s what he told us:

Dear FCPA Blog,


Very nice analysis of Syriana in response to the movie that at least this reader had called out, following your post entitled “Sleaze in the Cinema, Take One.”  

In truth, the aspect of the movie I liked best is the original promotional trailer itself, of which I have shown a portion (after having received a license) at the start of anti-corruption compliance training to grab an audience’s attention (“for three points, name the movie; for five points, name three actors you’ll see; for fifteen points, recite the fifteen key words you’ll hear in the voice over” and I then stop the trailer at the 1.25” mark, after the oily Texas oilman’s rich [“NOT“] assertion “… Corruption is why we win!”).

I note that if Hollywood gave central casting to the FCPA in this 2005 movie, it surely is a sign of the importance of the issue. Of course, I make clear, as you have understood, that the movie is not reflective of the approach and experience today of most in the U.S. multinational business community – certainly, not of those in the company for which I work. Almost without fail, I am assured that the audience will then listen to the many legal and business imperatives for clear corporate policies and commitment to procedures on anti-corruption that follow.

Thus, while conceding that “five” may be too high a ranking given the film’s dark and jaundiced take on corruption, I would award at least four red flags to a movie trailer that can accomplish this goal in less than 2 minutes. This is especially the case for an audience in the regulated pharmaceutical industry in which I practice, which today may suffer from “compliance fatigue” as a result of the virtually continuous training employees receive to address the many many different and evolving standards required to ensure that operations in a heavily regulated industry are conducted in a compliant manner.
The “enthusiastic support” you may have read into my singling out the movie was more for the educational values of both the trailer and your terrific blog – of which I am a devoted and appreciative reader, than for the underlying message of George Clooney’s thriller.



Daniel Kessler



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