On Oct. 10, the Association of National Advertising sent a letter to its members sharing that the Federal Bureau of Investigation had contacted the ANA's outside counsel Reed Smith LLP about assisting with its investigation into U.S. media buying practices. Steve Miller, a partner at Reed Smith who has had limited discussions with the FBI regarding the issue, said one aspect may be deception between media holding companies and advertisers. "Hypothetically, Media Holding Company A owes an advertiser a rebate for the volume of purchases that they made and then through accounting dichotomy or deception or misleading conduct [the agency] tells them they didn't earn the rebates," Miller said. "Yeah there's sports tickets, entertainment, taking someone's family to the Bahamas, but those aren't really big-ticket items. Then you start to see a couple companies a little more overtly suggesting and finding ways to put direct cash into the media agencies pockets," the executive said. Why now?The executive said that while practices of bribery have been happening for decades, the practice has become more apparent through the globalization of media agencies and increased competition over the last 10 years. Miller said he assumes it was prompted by the ANA's 2016 K2 Intelligence report titled "An Independent Study of Media Transparency in the U.S. Advertising Industry." One media buyer saw political motivations, as in the Russian interference of 2016 election via Facebook and other platforms, as a reason for the timing of the investigation. Miller imagined a scenario with two executives - Joe and Allen - in a media agency: Joe emails Allen, "We shouldn't be doing this," and Allen replies, "They'll never find out." Asked if that's a common practice, the executive in online advertising emphatically said, "Yes.". Read more