One of area that is an important part of a minimum best practices compliance program under the Foreign Corrupt Practices Act (FCPA) or the UK Bribery Act is risk assessment. Indeed in a recent video podcast on the site MainJustice.com, Kimberly Parker, a partner at WilmerHale, said that both the Department of Justice (DOJ) and the UK Serious Fraud Office (SFO) have made clear that a risk assessment is now the key initial step in crafting a compliance program under either the FCPA or Bribery Act. However, from information available to-date, it is not clear how JPM may have assessed its risk which led to it instructing its traders to make such risky bets. Yet the Bank must have thought its risk was quite high to bet up to $200MM per day the other way in an attempt to manage said risk.