Tom and I discuss HP, NCR & how NOT to react to whistleblowers, the new and improved DOJ web site, Comverse Technologies and a lenient sentence for Paul Cosgrove. Episode #53.
00:39: More than you wanted to know about Howard’s new site (the redesigned Open Air Blog)
01:51: Have a happy new year
02:55: Hewlett Packard (Howard recuses himself from the discussion, so this is all Tom)
06:09: You missed my birthday. Don’t worry, you don’t have to apologize
06:43: NCR shows considerable skill at treating a whistleblower complaint in exactly the wrong way. Tom & I talk about how to handle a whistleblower better. And here’s the link to Mike Volkov’s video.
18:12: DOJ improves their already-great Web site. And they work really, really hard
23:07: Tom is speaking in Singapore. If you’re anywhere close, you really need to go. Here’s the link to the conference. And in San Diego. The San Diego one is on diligence, and is with Mike Volkov
27:32: Comverse: we can’t guarantee that we won’t screw up…again. Ooookkkaaaayyyy, Comverse. Thanks for sharing. And how to actually have consistent messaging.
36:44: Paul Cosgrove, former global head of Sales at Control Components, Inc. (CCI), gets sentenced. Ending a very interesting case. And neither Howard nor Tom are Supreme Court scholars. Little help, anyone? And Howard is going to be in the same room with Lanny, in the near future, in London!
A shorter episode this week, in episode #47 Tom and I talk about the virtues of a free press, checkbook journalism, the effect of foreign law on US regulatory decisions, how to choose FCPA outside counsel, and more!
02:15: No enforcement actions this week, no new investigations
02:47: News Corp., phone hacking, the Leveson Committee, and we’re shocked, shocked, to find that there’s gambling going on in this establishment (wait, you mean that reporters pay for access?!). The intersection between the FCPA and a free press.
09:04: New law firm FCPA updates
10:36: if Germany says someone isn’t a government official, does that bind (or even influence) the DOJ?
15:25: law firm FCPA updates are too long, I argue
18:00: How to choose outside counsel for FCPA matters (Howard’s version)
26:37: Howard’s book comes out (okay, it’s Alexandra Wrage’s book; I just wrote a chapter).
27:43: New corporate disclosures (Qualcomm, Stryker, Schlumberger) show LONG investigations
32:11: Bistrong gets a recommendation of probation
34:17: The problem with sting cases
35:27: What’s a declination?
Just slapping it up, show notes to follow (at some point: I’m traveling for the rest of the week).
Tom and I talk about WalMart and their self-disclosure issue…no, wait…they don’t have a self-disclosure issue, do they?
We also talk about News Corp. (not the publisher of this blog…sorry, Sam), crisis management, willful blindness, and when’s it all gonna end?!
And we talk about when an in-house or outside counsel suddenly is cross-designated—without their knowledge or consent, much less additional salary—as a “government agent.”