Episode #51

In TWIFCPAVideocast on August 27, 2012 by Howard@OpenAir

In our weekly anti-corruption catch-up, Tom and I talk about Oracle, the SEC’s extractive disclosure rule, $50,000 to a whistleblower, who’s your state-owned entity, and Peterson accepts responsibility (except for that he doesn’t). And the highlight: NCR tipster lays out many, many lessons.

00:59: Howard promises not to say things are slow anymore
01:21: Oracle and the difficulty with finding and stopping slush funds
07:00: Howard agrees with Professor Koehler…what is the world coming to? Tom disagrees. Eh, he’s probably right.
15:41: SEC approves disclosure rules for extractive industry
20:56: SEC pays out first whistleblower payment
24:00: Tchenguiz case: we don’t understand the deal. Go over to Even we can understand that investigative agencies need resources to hire investigators. Call me crazy.
26:46: DOJ files 11th Circuit brief in Esquinazi & Rodriguez appeals
33:07: Is $34 million in one quarter a lot of money for an FCPA investigation?
36:09: Garth Peterson talks to CNBC and the SODDI defense
44:28: NCR: a world of issues in one little investigation (and Tom and I both have a senior moment. Little help here?). Killing the messenger is a time-honored custom in China, right?
55:21: Who is a “senior leader”? To what level does a bribery scheme have to rise in order for us to say that the company knew?
1:03:56: As if you needed another reason to go to San Diego, Tom and Mike Volkov are going to be speaking about due diligence. I speak at conferences too.

One Response to “Episode #51”

  1. […] the landing with the term the “SODDI” defense.  Thirty-seven minute mark of This Week in FCPA #51. Share this:EmailPrint Tags: china, garth peterson, morgan stanley About the Author Rajat Soni […]

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