One of the things not often mentioned in connection with Foreign Corrupt Practices Act commentary is the effect of dealing with corrupt foreign government officials, corrupt officers, and employees of state-owned enterprises and corrupt third parties. The problem with engaging in illegal conduct with any of these groups is that your company is now subject to blackmail and extortion if you stop making the illegal payments or in any other way ‘upset’ such actors. That was one of the takeaways I got from a New York Times story on the swirling Och-Ziff corruption scandal.
