Does the Green conviction signal that entertainment companies in particular are now going to be a FCPA target?
Yang: It’s more of a signal that if you are a company that’s involved in businesses in far flung places of the globe, or in some of these countries that have a particularly bad transparency record, then you are going to be part of a focus. As an American company, if you are trying to conduct business in a foreign country that is used to a completely different way of culture, you have to approach that minefield very carefully. Kubota: The DOJ has shown in other areas (like medical devices and the oil-services industry) that when it does a case in a particular industry, it takes its knowledge about practices in that industry and uses it to pursue other cases. Moderator: In the ’90s, white-collar defense was dominated by boutique firms. But in the last few years, the white-collar defense bar has shifted to international firms. Is this because of increased FCPA enforcement or are there other reasons for that? Farhang: Some of the things that happened in the past 10 years were Enron, Sarban
