Copies of releases issued regarding previous opinions are available on the Department of Justice's FCPA web site.Interestingly, very few companies have taken advantage of this "selling of indulgences" provision, as evidenced by the history of such activity since 1993 (click here to see the site). The "data exhaust" moment? Well, in nearly 17 years, the DoJ has issued a mere 34 "licenses to bribe" foreign nationals. There are no statistics detailing how many requests for a get-out-of-jail-free card were declined. If I were on some kind of congressional oversight committee (ie, if I had the patience to deal with acres of idiots), I'd be asking this question. Several possibilities emerge:
- The DoJ makes it hellishly hard to get the right to bribe; and/or
- The DoJ turns down a lot of requests; and/or
- The really smart bribery operations try to stay under the radar; and/or
- Major U.S. companies (and their highly paid attorneys) haven't done their homework to "know the ropes"