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Tom Fox: The FCPA has a starring role . . . . on Broadway!

In New York I recently saw the theater production of the new David Mamet play China Doll. As you might expect from any Mamet script, it is about rapid-fire language. 

Al Pacino plays the lead. From time-to-time, he was that cool controlled Pacino who graced us as Michael Corleone. More rarely he was Tony (let me introduce you to my little friend) Montanze from Scarface. For any of those moments the play was worth it.

If you have made it this far in this post and want to see the play, be prepared for a spoiler alert.

If you’re not going to see the play, no worries.

But here goes: A significant plot device turns on, of all things, the Foreign Corrupt Practices Act.

Imagine my utter shock when Pacino’s character was told he would be charged with violating the FCPA because a company in his supply chain had paid a bribe to have Pacino’s financé perform design work on an airplane that Pacino had custom ordered.

We first had a movie (Syriana) that featured the FCPA as a plot element, and then a television show (House of Cards). And now we have a Broadway theater production.

When art begins to imitate life, it certainly speaks to the ubiquitousness of the issue. 


Thomas Fox is a contributing editor of the FCPA Blog and a Compliance Week columnist. He’s the founder of the Houston-based boutique law firm A popular speaker on compliance and risk-management topics, Fox is also the creator and writer of the widely followed FCPA Compliance Report. His book Lessons Learned on Compliance and Ethics topped Amazon’s bestseller list for international law. He can be contacted here.

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  1. Hollywood has first-hand experience with the FCPA, which may be why it has found its way into movie scripts and Broadway plays. In 2009, the United States Attorney's Office in Los Angeles successfully prosecuted two film producers, Gerald and Patricia Green, for bribery schemes to get valuable contracts, including rights to manage and operate Thailand's yearly film festival, from the Thai Government. The Greens were sentenced to 6 months in jail.

    Since then, the SEC has conducted a sweep of the movie industry and its activities in China. In 2012, the SEC sent letters of inquiry to 7 major Hollywood studios — Twentieth Century Fox, Paramount Pictures, Sony Pictures, Universal Pictures, Walt Disney Studios, Warner Bros. and DreamWorks Animation. In 2013, the SEC escalated its inquiry of Sony Pictures by issuing a subpoena targeting potential bribery related to Sony's 2010 release in China of "Resident Evil: Afterlife."

    Writers write about what they know. So long as bribes are given to expedite filming on location in foreign countries or to avoid censorship and quotas in China, the FCPA will continue to find its way into story lines and plot twists. Through its enforcement efforts, the SEC is continuing to keep the FCPA at the top of Hollywood's and Broadway's mind.

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