The first Opinion Release of 2011 is out, No. 11-01, and it certainly may leave compliance practitioners scratching their heads. However, this collective head scratching is not because the Opinion Release is so difficult to understand and has no application to the everyday business of compliance, but for a polar opposite reason – the question posed to the Department of Justice (DOJ) is so straight-forward, and has been previously asked and answered, that it is difficult to understand how any first year compliance practitioner did not know the answer to it. So while I generally try not to skewer such matters the way my ‘This Week in the FCPA’ colleague Howard Sklar occasionally does, I do have to admit to some befuddlement.