It certainly is good work if you can get it. As reported in the Financial Times, Abdul Razak Baginda was paid over €30 million for work as the middleman in a transaction between the French company Thales International Asia and Malaysian government for the sale of two submarines. The article said, “Mr. Baginda told the FT he was paid about €30m to consult on the French deal, lobby for it and oversee 8 years of execution.” There was no report on whether there was actually a signed contract which might specify Baginda’s duties.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...