The Day the Music Died: Compliance Convergence and the Lacey Act

Thomas Fox

Most people will recognize the name of Gibson Guitar, one of the most widely known makers of guitars in the United States. Unfortunately the company was recently raided by the US Fish and Wildlife Service for a failure in the compliance arena. However, it was not for a violation of the Foreign Corrupt Practices Act (FCPA); UK Bribery Act; OFAC or other more widely recognized anti-corruption statutes. Gibson Guitar was raided through an investigation regarding alleged violations of the Lacey Act. As reported in the September 1 edition of the Wall Street Journal (WSJ), in an article entitled “Gibson Guitar Wails on Federal Raid” James Hagerty and Kris Maher reported about an August 24 raid by the US Fish and Wildlife Service. All of this reminded me of my ‘This Week in FCPA’ colleague Howard Sklar’s multiple discussions of compliance convergence.

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