There Must Be Fifty Ways to Leave Your Agent
A publication in Foley’s International Trade, Enforcement & Compliance series.
Happy Thanksgiving! As anyone who saw our Halloween International Trade Update is aware, we are all in favor of alternative ways to get out our international regulatory compliance message. So, who better to aid in our holiday-themed compliance quest than two-time Rock and Roll Hall of Fame inductee, sixteen-Grammy-Award winning songwriter Paul Simon, who actually spent a semester in law school before deciding — for some reason — that he might be more successful as a song-writer and recording artist.
Unfortunately, Mr. Simon never chose to merge his two interests, thereby missing a golden opportunity to remind the world in the catchiest possible way that monitoring and auditing third parties for anticorruption concerns is a time-honored way of mitigating FCPA risks:
There Must Be Fifty Ways to Leave Your Agent
The problem is all with your agent
She said to me
Compliance is easy if you
Take it logically
I’d like to help you to stay
Indictment free
There must be fifty ways
To leave your agent
We all know how Justice will intrude
Using theories that are strange and oh so misconstrued
But I’ll repeat myself
At the risk of being crude
There must be fifty ways
To leave your agent
Fifty ways to leave your agent
[CHORUS]
You just don’t renew, Stu
Revoke ab initio, Joe
Don’t be willfully blind, Hyde
To stay DOJ free
Don’t ignore those red flags
And agents with moneybags
Stay away from bribery, Lee
To stay DOJ free
She said we need to ensure
That SEC accounting gnomes
They stay well within
their GAAP accounting homes
Let them choose another target
To play Watson and Sherlock Holmes
There must be fifty ways
To leave your agent
She said it grieves me so to see painful DPAs
Firing bad agents is the way to keep them all away
I said I appreciate that
And would you please explain
About the fifty ways…
She said why don’t we both just sleep on it tonight
Third-party liability is not such a pretty sight
And as she left, I realized she probably was right
There must be fifty ways
To leave your agent
Fifty ways to leave your agent
[CHORUS]
You just give him the sack, Jack
Have an audit plan, Stan
Don’t pay cash in Croix, Roy
To stay DOJ free
Don’t pay him with slush funds
Unless you like Feds with guns
Stay away from bribery, Lee
To stay DOJ free
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