For years now, a certain reader has been stitching together for us enforcement topics in ways we hadn’t thought of.
This time our friend — who’s a top compliance professional and wants to remain anonymous — connects the dots from a few recent headlines.
Does he have an over-active imagination? It’s tempting to think so. Except he’s been spot on more times than we can count.
Here’s what he said this week:
Dear FCPA Blog,
Fascinating post last Friday about Wikileaks and the FCPA. I believe like you that there is potential for these leaks to implicate or at least provide fodder for those interested in FCPA enforcement.
However, I also wondered how this might apply or relate to the new FCPA whistleblower provisions (if at all). Perhaps if Wikileaks was smart it would turn this information over to the SEC and it may not have to worry about its on-going funding challenges.
(Ever since I first heard of Wikileaks, I thought it would be the perfect forum for corporate whistleblowers to come forward.)
The other aspect is the Giffen effect, where these payments may be state sponsored and therefore problematic from an enforcement perspective. Obviously the situation would not be pretty no matter how you slice it.
We’ll see if anything comes out. I understand those news organizations that got a sneak peek are still reviewing the documents.