Howard@OpenAir
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SEP
06
Where I Am Now
By:
Howard@OpenAir
on
SEP
06
I’ve moved! Open Air Blog is now on the Svbtle platform. It’s an easy fix: just go to openairblog.com! Don’t worry, I’ll keep reminding you.
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AUG
13
Best. Quote. Ever.
By:
Howard@OpenAir
on
AUG
13
Preparing for This Week in FCPA today, I came across this quote in the New York State Department of Financial Services’ Order against Standard Chartered: You fucking Americans. Who are you to tell us, the rest of the world, that we’re not going to deal with Iranians. This was from SBC’s Group Executive Director to […]
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AUG
07
Ambitious Is Good: FCPA World Monitor
By:
Howard@OpenAir
on
AUG
07
Via the Professor, I’ve read some posts by Rajat Soni, a lawyer who has entered the FCPA Commentariat with his FCPA World Monitor. Claiming to monitor the world is ambitious, but then again, I like ambitious. Truth be told, I’ve read of couple of posts of Soni’s and I disagree vehemently with both of them. […]
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AUG
06
The Importance of Context
By:
Howard@OpenAir
on
AUG
06
Here’s a sample of the kind of thing I post on fcpa.tv. You can go to that site, or you can subscribe on iTunes here and watch it on your iPad. I talk about the importance of context in evaluating potential FCPA violations. No inappropriate behavior occurs in a vacuum. Companies who can show that […]
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AUG
06
Counting to 10, Internet Fact-Checkers, and Integrating Acquisitions
By:
Howard@OpenAir
on
AUG
06
I had a boss at the SEC that used to make us read and research all the boilerplate language we put in briefs. He was right, and I forgot his lesson. I spend 1,000 words setting the record straight.
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AUG
03
Unrealistic Expectations: Training Third Parties
By:
Howard@OpenAir
on
AUG
03
Nordam's recent non-prosecution agreement required them to train their third parties, of any kind, including up to the Board. Really? I talk about why that's a stupid thing to agree to.
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AUG
01
FINCEN & Customer Due Diligence
By:
Howard@OpenAir
on
AUG
01
I'm looking for someone to talk to who was at the public hearing on the new FINCEN regulation. The one that requires collection of beneficial owner information.
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JUL
23
Monterey
By:
Howard@OpenAir
on
JUL
23
I’m in Monterey, CA this week for the Carmel Valley eDiscovery Retreat. First day is almost done. Nary an FCPA question to be found. Here’s one for you. I’m still marinating over the Jackson & Ruehlen briefs, and some of the arguments that were made. One of the arguments Ruehlen made was about the pleading […]
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JUL
18
Arguments I Don’t Like
By:
Howard@OpenAir
on
JUL
18
I was still coming off the rant the other day when I was reading the Reply memoranda of Mark Jackson and James Ruehlen in the Noble follow-on actions. Mistake. It’s a little like going into the grocery store when you’re hungry; you end up over-spending. And to a certain extend, Jackson’s and Ruehlen’s arguments are […]
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JUL
16
“The Limit Should Be Zero Dollars”
By:
Howard@OpenAir
on
JUL
16
What's the fastest way to crumble your reputation to dust? Say something like "the limit [for hospitality] should be zero dollars. That will keep you safe." No. That won't keep you safe.
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