“[I]t’s one of the Commandments of Good Journalism: Thou shalt not pay for information.  Only the tabloids, of both the supermarket and TV variety, regard news as a tradable commodity,” according to an article in the American Journalism Review.  Unfortunately, those Commandments are not always followed.  Generally, journalists pride themselves on not paying or giving favors for interviews or access to information.  But sometimes journalists feel pressured to do so.  When they do, such actions may not just implicate journalistic ethics, but the FCPA and laws like it, with harsh consequences such as penalties, disgorgement of profit (perhaps advertising revenue) and possible loss of FCC licenses.  Bribery in journalism may work the other way too.  It can be the journalists – foreign officials in many countries where the media is state-owned – taking the bribe from companies who want media coverage, creating liability for non-media companies.  Corruption in newsgathering may not be intuitive, and in today’s competitive media environment, it can be difficult to prevent.  This article examines (with expert input from Dan Rather and others) corruption risks newsgathering can pose; situations where journalists and their employers can, and have, faced potential FCPA violations; compliance policies companies have implemented; and seven measures media companies can take to improve their compliance programs and mitigate corruption risk.