This is more of a general comment . . . .
I would (also) like to add my appreciation to the individuals behind this useful and interesting site. It is a great resource for further experience and knowledge in an area where the expertise is limited.
Through the company I work for, I have been directly involved with several findings of illegal payments and FCPA violations, including the start of a Swiss company's operation under questionable procedures in Nigeria and Angola. And, as part of these years of Compliance and FCPA experience in the oil & gas business (specifically directed to oil & gas), it has become clear that the legal community does neither have the operational skills or experience and knowledge to fully support, implement and follow through on a process as required by the DoJ. To cover the interpretation and advice, yes, but to fully support in implementing a successful program which proactively address and prevents future compliance incidents the operational understanding is lacking.
From experience the legal community does not have the required understanding within logistics, suppliers, cultural differences, internal employees etc.
The industry must understand that compliance (FCPA/integrity/ethics) is not a project which may be outsourced for a short period of time. One reason being the 3rd party legal advisors do not have the necessary knowledge of how to successfully implement such a comprehensive culture change in an industry as oil & gas. But mainly because the internal resources must be educated, starting with the top management clearly address the seriousness of the issue.
We have pursued different alternatives in my company, but none has been more successful when using the internal knowledge and operational experience, along with the advice from legal resources.
My proposal to the acknowledged Compliance / FCPA law firms, would be to include individuals with experience within the oil & gas industry to fully support in educating and cleaning up the industry.
Merely a suggestion based on experience under the watch of the DoJ.