The Global Investigations Review quoted Barak Cohen in "Broad Use of Crime-Fraud Exception Could 'Severely Undermine' Attorney-Client Privilege'" regarding a Third Circuit ruling concerning prosecutors' use of the crime-fraud exception to pierce the attorney-client privilege in a Foreign Corrupt Practices Act (FCPA) matter. Cohen described the Third Circuit decision as "scary." "Most lawyer-client consultations involve, at least at some point, lawyers advising clients regarding information about the types of conduct that may violate the law," he said. "Here' that's exactly the sort of information that the Third Circuit decided can provide a "reasonable basis" to conclude that a client sought legal advice to further crime or fraud."