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Media Trading Practices Under FBI Scrutiny

According to Campaign, the FBI may be reviewing media trading and transparency practices in the US, and focusing on specific media companies and any role played by executives.

The article reports that neither the FBI nor DoJ will confirm or deny any activity around the matter.

However, it’s been a widely held belief that some action by the DoJ would take eventually place after the Association of National Advertisers (ANA) and its third party auditors issued its K2 Report (June 2016) claiming that media agencies in the US were, to varying degrees, pocketing media rebates and lacked sufficient transparency in their media buying practices.

According to an AdAge article published on the heels of the report’s release, K2 “cited 150 independent sources and ‘substantial evidence’ from 41 sources who reported direct knowledge of rebate deals occurring in the U.S. market. Of those sources, 34 indicated rebates were not disclosed or returned to advertisers.”

The report, however, does not name any agencies or media vendors, and according to the ANA, five of the six major holding companies at the time refused to make any of their executives available for interviews by its auditors.

The 4A’s leadership and some holding companies rebuked the report, citing a “lack of transparency” in the ANA’s investigative process as well as the report itself.

It’s been two years since the K2 report was released, yet according to a presentation by McKinsey at the ANA’s recent Financial Management Conference in Hollywood, Florida, the problems with media transparency and pocketing rebates is still pervasive despite a push by advertisers for greater transparency into the process.

Perhaps this is why larger advertisers are taking part or all of their media investment management in-house.


Bajkowski + Partners LLC is a leading consultancy providing services to marketing and procurement teams including building in-house media planning and programmatic as well as in-house creative and production operations.