Archive for the ‘Compliance Defense’ Category

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Episode #43

In Chadbourne,Compliance Defense,Data Systems & Solutions,Debarment,Jon Jordan,SEC,Stroz Friedberg,UK Bribery Act on July 5, 2012 by Howard@OpenAir Tagged: , , , , , , , , , , ,

Show notes:

00:48: should the DOJ throw an elbow? I explain my post, here. Is the DOJ a regulator or prosecutor? Would a compliance defense change that? (@09:35). False Claims Act & Federal Acquisition Regulations discussed at 12:14.
19:12: I discuss my next article for Forbes.com. Should there be a distinction between public and private?
20:10: Jon Jordan’s article on the compliance defense, and he gets “FCPA Voice Rookie of the Year” award for 2012. Last year was Matt Ellis.
30:44: How can the business community partner with the DOJ? Should the DOJ adopt the OFAC informal opinion process?
35:57: Why I hate bribery. A toddler dies because the ambulance driver demanded a bribe.
42:27: UK Bribery Act…who cares? Deloitte survey. Oxford University Press case at 47:10.
53:32: Data Systems & Solutions enforcement action
1:00:18: Scott Peeler goes to Stroz Friedberg
1:02:25: SEC serves papers on Germans via publication in the International Herald Tribune

Articles

Episode #41

In Africa Sting Case,Compliance Defense,Compliance Week,Procter & Gamble,TWIFCPAVideocast on June 11, 2012 by Howard@OpenAir Tagged: , , ,

Show notes:

00:50: Compliance Week
03:17: CEO of P&G gives a speech, and we ask, “do you need a CCO?”
11:18: Companies are taking a look at their specific risks, and that’s a good thing
13:54: What does any of this have to do with a compliance defense?
16:16: 8 moms give Bob McDonald (the CEO of P&G) agita
17:52: Tom and I go to an ABA panel on the Africa Sting case
24:30: Mike Koehler is going to law school
26:06: Hewlett-Packard’s latest disclosure

Articles

Episode #24, plus the FCPA Professor on a Compliance Defense

In Compliance Defense,Finmeccanica,Lindsey,Olympus,Pfizer,red flags,SFO,TWIFCPAVideocast,UK Bribery Act on December 5, 2011 by Howard@OpenAir Tagged: , , , , , , , , ,

Well, I thought I had figured out why the titles were coming on at the wrong time, but I was mistaken.  Hmmm…maybe this show will get dismissed.

Tom and I are back from vacation and raring to go.  The first section—about half the show—we spend on the Lindsey case.  I end up on a bit of a rant.

We have a breakout session on the Compliance Defense with none other than the esteemed FCPA Professor, Mike Koehler.  Agree with him or no, there’s no one more knowledgeable anywhere in the world about the history of the FCPA.

Show Notes:

  1. Lindsey, starting at 1:45, takes up a significant amount of time (about 28 minutes)
  2. Olympus starts at 29:47 (almost 3 minutes)
  3. Alstom starts at 32:38 (4 1/2 minutes)
  4. SFO Red Flags starts at 37:06 (1 1/2 minutes)
  5. Pfizer starts at 38:45 (6 1/2 minutes)
  6. Finmeccanica starts at 45:33 (about 2 minutes)

Full episode (despite the bars, go ahead and hit play.  I’ll work):

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

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Breakout/Conversation/Debate on a Compliance Defense to the FCPA

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