The standard for culpability under the FCPA is perception. If there is a hint, then you're probably going to face some action. If I sound paranoid, sorry - that's my basic reading of it - it is paranoid.

It's interesting because I have some exposure to law-firm ethics ( I wrote software for law firms for a while decades ago ) and they're like this. Their admins ( who really run law firms ) are past masters at dealing with it. Since it's lawyers writing that law, we should not be surprised.

You get a (distorted for the purposes of plot-conflict) view of that in "Better Call Saul."