One of my favorite lawyer songs is the Warren Zevon classic “Lawyers, Guns and Money”. I was reminded of that song when I sat on a panel on Wednesday with Dan Chapman and Mike Volkov, where we discussed recent enforcement actions and due diligence under the Foreign Corrupt Practices Act (FCPA). Dan is the Chief Compliance Officer (CCO) at Parker Drilling here in Houston and one of the points he raised was the company’s need to put their outside counsel through FCPA due diligence similar to other vendors. He said that law firms would yell, scream, kick and whine vociferously that their collective honor was being questioned but Dan made clear that foreign (and sometimes US) outside counsel often deal with foreign governmental officials.
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