“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 death of Cecil the Lion. These third parties obtained various governmental permits from the Zimbabwean government to allow him to hunt in that country. These same third parties acted as hunting guides to Palmer and are alleged to have lured Cecil the Lion illegally off a protected game reserve through criminal conduct in violation of Zimbabwean law.
All of this conduct could be violations of the FCPA, and Palmer could face five years in jail for each FCPA violation.”
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