Partner Philip Urofsky (Washington, DC-Litigation) and associate Jessica Bartlett (New York-Litigation) have published an article, titled "Effective Corporate Compliance and the Irrelevant 'Foreign Official' Debate," in the January 11, 2013 edition of Bloomberg BNA's White Collar Crime Report.

The article argues that an undue focus on whether the recipient of benefits, including marketing gifts and hospitality, is an employee of a government “instrumentality” and thus a government official for purposes of the FCPA diverts valuable compliance resources from preventing both public and private corruption and may, in fact, render a corporation’s anti-corruption program ineffective.

View full article, "Effective Corporate Compliance and the Irrelevant 'Foreign Official' Debate"