Archive for the ‘Avon’ Category


Episode #48

In Africa Sting Case,Avon,Halliburton,Olympus,SEC,Stroz Friedberg,TWIFCPAVideocast on August 3, 2012 by Howard@OpenAir Tagged: , , , , , , , , , , , ,

A busy FCPA week: investigations starting, investigations ending, CEOs asked to come in for interviews, Stroz Friedberg picks up another one, and a rant about CDOs, the financial crisis, and dumb money.

Show notes:

02:47: Investigation of Sensata closes, no charges brought; raises the question of “what’s a declination, exactly?” And how you need M&A diligence.
14:00: WW Grainger publicly announces that they don’t know how to do an internal investigation. That is, they announced that their investigation didn’t find anything. What should you do with gift cards? And why a compliance culture is good for the business.
22:31: Halliburton opens an investigation
26:12: Olympus open an investigation. Into reimbursements to doctors in Brazil. Really? You’re gonna disclose that?
28:04: The importance of integrating companies you buy
33:05: Total SA. Howard goes on a rant, and evidently isn’t a fan of anything French.
40:15: Still on Total SA, but talking about how the investigation is REALLY old, and as someone told me, cases—unlike wine—don’t get better with age. Plus, the blocking statue; plus, the whistleblower laws.
43:03: Avon’s CEO gets called in, and Avon has spent a ton of money. Seriously, if you weighed it, it would weigh a ton.
49:25: Bistrong gets 18 months. Howard feels conflicted.
54:21: Stroz Friedberg shoots…they score! Again. First Scott Peeler, now David Glockner.
56:47: SEC loses Stoker trial. Howard tries to explain what a CDO is (and fails miserably).


Episode #21, Plus a Breakout on Audit Rights

In Alcoa,Audit Rights,Avon,Dadeleh,disclosure,Esquinazi,Haiti Telecom,InVision,Pillor,SEC,Tognum,TWIFCPAVideocast on October 31, 2011 by Howard@OpenAir Tagged: , , , , , , , , , ,

Once again, Tom and I keep our breakout session short (exactly 10 minutes!), and this week it’s on audit rights.  We’ve argued about this before, so this is familiar territory for us.

Show  Notes:

  1. Esquinazi Sentence (14 minutes): starts at 1:40
  2. Avon discloses an SEC investigation (9 1/2 minutes): starts at 15:55
  3. Dadeleh arrest and more on Aloca/Alba (11 1/2 minutes): starts at 25:21
  4. Innospec arrest (4 minutes): starts at 37:42
  5. SEC v. Pillor and individual liability for aiding and abetting (12 minutes): starts at 40:35
  6. Tognum (5 minutes): starts at 52:44
  7. Equitorial Guinea (just a mention)(15 seconds): starts at 57:55

Full episode:

[vimeo w=500&h=400]


————————Breakout Session Below——————————–


Breakout on Audit Rights: total time is 10 minutes even.

[vimeo w=500&h=400]


Episode #2

In Avon,Rockwell Automation,TWIFCPAVideocast on May 8, 2011 by Howard@OpenAir

Here we are, another episode of This Week in FCPA.  Be forwarned, it takes a minute or two to load: it’s a big video file.

Here are the episode notes:

Pharma Industry Sweep
Defense challenges to enhanced audio at trial
Rockwell Automation
Objection to Alcatel-Lucent DPA by Mexican Telephone
Russia Anti-Corruption Law

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