Howard@OpenAir
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Programmatic Issues
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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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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JUL
09
Schedule C, Element #5
By:
Howard@OpenAir
on
JUL
09
At this rate, I know, it’ll take quite a while to get through all 13 steps. But one small step at a time. Today’s step is all about reviewing your program on a regular basis. I want to lay out the importance of this element first, then go into the specifics. Not too long ago, […]
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APR
24
Defending Wal-Mart
By:
Howard@OpenAir
on
APR
24
I’m thinking that if I wanted to cement my standing as the reigning anti-corruption iconoclast, a headline like this one would do it. In the face of the indefensible, let me offer a defense. Or, at least, some mitigating facts which you should take into account. The overriding thing I thought of when I read […]
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APR
17
The Nightmare Scenario
By:
Howard@OpenAir
on
APR
17
Please tell me where I go wrong here, because this is something I’ve been worried about for a long time. So much so, in fact, that I call it my “nightmare scenario.” It might be unlikely, but legally, am I wrong to worry about this? And if legally correct, what’s the best argument about why […]
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APR
03
You’re Hired. Now What?
By:
Howard@OpenAir
on
APR
03
One of the pieces of advice I regularly give to compliance people wanting to know “where do I start?” is to pick a place and start. The act of starting brings its own momentum. And there’ll be enough to do that you can start anywhere. Like in military parlance, any action is better than none. […]
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MAR
06
What Does the DOJ Expect From You: Schedule C Explained
By:
Howard@OpenAir
on
MAR
06
This FREE 3-Part webinar series will provide a step by step guide to ‘Schedule C’ – a list of elements found in recent deferred prosecution agreements by the Department of Justice (DOJ). Register HERE for times convenient to Asia. (It’s noon, Singapore time, over one day a week for three weeks.) In this webinar series I […]
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FEB
17
Reading the Tea Leaves
By:
Howard@OpenAir
on
FEB
17
There is absolutely no percentage in disagreeing with Mike Volkov. Besides being—and I don’t use this word all that often—brilliant, and an experienced practitioner, and a former prosecutor, and just a heck of a nice guy, he’s usually right. But with a slight tremor of my fingers on the keys, let me venture into this […]
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JAN
03
Teachable Moments
By:
Howard@OpenAir
on
JAN
03
Rather than do a standard “10-most…” post, I thought I’d do something different. It’s still my way of conveying the most important lessons of 2011, but because I’m by nature a contrarian, I’m going to do a list of 5 rather than a list of 10. Can’t you just taste the counterculture? By “teachable moment,” […]
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NOV
29
Scare the Crap Out of Them
By:
Howard@OpenAir
on
NOV
29
I’m taking a page from my colleague Ralph Losey (let there be truth between us: I’ve met him once and talked to him twice, but he’s a “colleague” in the general sense, and I’m entitled to a little literary license, no?). In a recent piece, Losey wrote about the dirty little secret of attorney incompetence […]
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