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.

This matter came to light because French prosecutors are investigating the transaction to determine if, the former President of Thales International Bernard Baiocco paid kickbacks to the embattled Malaysian Prime Minister, Najib Razak to facilitate to the transaction. The Prime Minister is currently under investigation for his roles in other corruption scandals, although the Malaysian government entity charged with the investigation has cleared him of any criminal violations. Baginda was Thale’s agent on the transaction.

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...