This is certainly not the first time these pages have addressed this topic, but it keeps on happening, so I will keep on writing about it.

For profit companies that host FCPA conferences are entitled to run their business as they see fit. However, when for profit companies use Foreign Corrupt Practices Act officials at the DOJ, SEC, and other government agencies 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.

The most recent example is this release from American Conference Institute touting its upcoming “Official Conference of the Global Anti-Corruption Community.” (What does that even mean? Are other FCPA conferences or conferences in which the FCPA is discussed “unofficial”?).

Below are several screen shots from ACI’s website and its social media accounts.

What will it cost you to hear your public officials speak, to hear their supposed “key updates” and for them to “address audience questions”?

According to the conference website:

It is bit ironic that these conferences focus on FCPA topics, yet the problematic conduct highlighted above occupies the same general space, and is marketed in plain view including ACI’s pitch that it paid customers will “benefit” from a private “open Q&A” with your public officials.

In addition, those with FCPA experience including conference co-chairs Daniel Kahn (Davis, Polk & Wardwell and former FCPA Unit Chief), Una Dean (Vice President, Assistant General Counsel, Head of Global Investigations at IBM), and Justin Siegel (Vice President, Global Head of Conduct and Integrity) are actively inviting you to attend this event (see here for the video).

In addition, the event has numerous corporate sponsors including law firms with FCPA practices. (See below for the lead sponsor and supporting sponsors).

In addition, according to the conference website it has an advisory board of twelve individuals including several individuals well known in the FCPA space.

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 market and sell.

Moreover, public officials need to stop allowing themselves to be used as pawns by for profit companies.

Moreover, those in the FCPA space need to spot supporting and aligning themselves which such practices. Far from enhancing their professional reputation, the opposite is occurring in the eyes of some.

These are all serious issues that deserve more attention and corrective action.

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