Posts Tagged ‘Wal-Mart’

Articles

Episode #37

In Carson,News Corp.,Self-disclosure,Wal-Mart,Willful blindness on May 11, 2012 by Howard@OpenAir Tagged: , , , , , , , , ,

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.”

Enjoy.

[vimeo http://vimeo.com/41740155 w=768&h=640]

Articles

Episode #35

In TWIFCPAVideocast,Wal-Mart on April 24, 2012 by Howard@OpenAir Tagged: , , ,

All Wal-Mart, all the time.

I’ll try to parse out the subjects we talk about by time.  It blends, so bear with it.

04:00: Will this fundamentally change FCPA compliance going forward?
06:06: How will Mexico respond? How will the DOJ?
07:11: Impacting the News Corp. story
08:22: Will this kill the FCPA reform movement?
Vis-a-vis: (1) Compliance defense (2) respondeat superior (3) defining “foreign official”
12:45: Were the people receiving the payments foreign officials?
13:10: My take on the effect on reform efforts, and how the Chamber could turn this to their advantage
25:30: Were these facilitation payments?
30:30: Legal under local law exemption? And how does the local law element interact with the facilitation payments element? And what does Mexican law say?
34:18: Books-and-records issues. A “legal facilitation payments” account? Good idea?
37:35: Self-disclosure. What happened?
44:12: What happened with the internal investigation?
50:25: What did Wal-Mart do right?

By the way, I mistakenly recorded this as picture-in-picture rather than side-by-side.  At least the relative weights of the opinions presented are reflected in the size of the window.

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