However my “This Week in the FCPA” colleague, Howard Sklar, speaking in our Episode 12, suggested that there might be another aspect to this specific Opinion Release that I had not considered. While I had discussed the above points from the perspective of an outside counsel, in-house lawyer or compliance office who specialized in FCPA compliance work; the Opinion Release Procedure is designed so that any person or company may submit a query to the DOJ. Howard suggested that the Opinion Release Procedure could be utilized by a company which does not have either an in-house compliance practitioner or even a General Counsel. A question can be submitted to the DOJ as straight forwardly as with a one page document setting forth the information required under the Opinion Release Procedure.