Securities and Exchange Commission Historical Society
Looking Back


1974 Stanley Sporkin and Ray Garrett, Jr.

"It is clear that the questionable payments problem must be taken seriously. The number of U.S. firms implicated has been relatively small, but the pattern of improper behavior involved cannot be tolerated. It is totally inconsistent with American values. It threatens to harm our foreign relations. If allowed to continue, it could badly erode public and international confidence in American business and American institutions."

- June 14, 1976 White House Release: Statement by the President on Questionable Corporate Payments Abroad

Out of the Watergate scandal came an unrelated revelation: hundreds of companies had illicitly funneled millions of dollars to foreign agents and officials. Few doubted that such payments should be prohibited, but many wondered about jurisdiction and enforcement. Some considered protecting the integrity of financial reporting more important than prosecuting bribery. Political friction abounded as Congress, the U.S. Securities and Exchange Commission and the White House all grappled with these issues.

Stanley Sporkin, Director of the SEC Division of Enforcement, was watching the Watergate hearings when he realized that the corporate political payments being discussed must have been made without proper disclosure. His staff uncovered secret slush funds that had been used not only for political purposes but also for commercial endeavors abroad. Visit the Three Approaches, One Law in Wrestling with Reform: Financial Scandals and the Legislation They Inspired Gallery for primary and original materials and information on the development and 1977 enactment of the Foreign Corrupt Practices Act.

"The thing that has given me great pleasure is to bring to a meeting with you an inside General Counsel or CEO who has heard that you are a devil or madman and then hear him report to his board that you are hardly an unreasonable person."

- May 7, 1977 Letter to Stanley Sporkin from Manuel Cohen

Oral Histories


June 1990 James Doty at the Berlin Wall

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