Celebrities In Peril!

“Anyone in the compliance industry knows that with high pressure and big money comes risk,” writes Harry Cassin in FCPA Blog, and he wonders if 2023 will be the year when the first “influencer” faces a Foreign Corrupt Practices Act case. Influencers are social media stars, often because they are famous in other areas of endeavor, quarterbacking football teams, for example, or in the case of influencer Kim Kardashian, simply famous for being famous. Kardashian famously agreed to pay the SEC $1.26 million to settle charges of promoting cryptocurrency to her Instagram followers without disclosing that she was paid for the promotion last October. Influencers can rake in millions of dollars, and often run companies dedicated to supporting their efforts to create click-bait. In other words, influencing is an industry, and as Cassin observes, no industry is immune from the FCPA. “Will we see the first influencer-related FCPA case in 2023? Stay tuned,” he suggests.