But Everyone Else is Doing it

In my hasty post on last week’s FCPA sting operation my focus was on the aggressive use of an undercover operation to catch violations of the Foreign Corrupt Practices Act. That was big news. It’s the first time that’s happened. The indictments did not disclose the companies involved.

It’s now clear that this sting operation was much bigger deal. The Department of Justice went after an entire industry. Richard Cassin dug around and found that those arrested came from dozens of different companies. Small companies, big companies, private companies, public companies.

Twenty-one of the arrests happened at the Shooting, Hunting, Outdoor Trade Show and Conference (SHOT Show), “the largest and most comprehensive trade show for all professionals involved with the shooting sports and hunting industries.” The SHOT show attracts tens of thousands of people from across the US and the world, with 1,800 exhibitors covering 700,000 square feet.

The sting was clearly a statement that the Department of Justice is not going to take an excuse that “everyone else is doing it.”

It does not matter if greasing palms happens to be a common way to transact commerce in the industry. They are willing to take on an entire industry. They are willing to use undercover operations. They are willing to make a big splash at a big media event.

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