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On the Death of Cecil the Lion and the FCPA

Tom Fox | August 11, 2015

Cecil the Lion was shot and killed in July. What does the death of this well-known and well-beloved lion in Zimbabwe have to do with the Foreign Corrupt Practices Act? More importantly, what are the lessons to be learned by any chief compliance officer or compliance professional from this event? Much more than you would first think, actually.

A U.S. citizen, Dr. Walter Palmer, a dentist who is a big game hunter aficionado, killed Cecil. As a U.S. citizen, he is subject to the FCPA anywhere outside the United States. Palmer employed third parties to assist him in obtaining a benefit, which in Palmer’s case was his hunt that ended in the...

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