Episode #39 is in two parts (my baby pulled out the plug to the router).
0:00 Happy Shavuos
1:45: It’s the Week of the Letter
2:01: Open Society Foundations letter to Rob and Lanny
3:00: What’s an “instrumentality”? More than 51% owned by government? Is that the right standard?
8:45: Public v. Private distinction: does it mean anything anymore?
13:53: Is there, or should there be, a de minimus gift exception?
15:25: Gift-related investigation disclosure by MTS
We lose contact around 17:45 or 18:00
0:00 Sorry about that
2:34: Congress writes a letter to the Chamber: are your members hopelessly conflicted. Hell freezes over: Tom, the FCPA Professor, and I are all on the same side of this.
5:38: DOJ writes to Congress about the Ted Stevens case. Were the 40-day suspension and the 15-day suspension sufficient? (@7:38: Williams & Connolly respond, harshly)
16:10: Ernst & Young 12th Global Fraud Survey
20:20: Dow Jones anti-corruption survey
22:27: Chadbourne & Parke Compliance Quarterly: Tom and I love it
27:35: The SEC has a lot of trials. Do they have the people to do them?
30:34: 7 Ways to Maintain Credibility with the DOJ in FCPA investigations (including, hire Recommind
38:39: a panel you might want to attend. Definitely worth the $195.