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Howard@OpenAir

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Ambitious Is Good: FCPA World Monitor

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. […]

The Importance of Context

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 […]

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 […]

Arguments I Don’t Like

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 […]

Everyone needs to keep up with the times. I attended a panel at Compliance Week where the former Chief Compliance Officer of Walgreens listed “pace of change” as one of the primary stressors of CCOs. This is especially true in the FCPA field, where new cases come out and new investigations are announced on a […]

Remember the Context

I’m at Compliance Week. You seriously wish you were too. It’s a fantastic conference. I was talking to a government official—one who deals with FCPA—who shall remain unnamed*, talking about gift-giving scenarios and why they were problematic, and how to handle them. Such as: situations where you’d be giving a benefit to the children of […]

Thank You For Your Service

For those New Yorkers who were here in the weeks following 9/11, one memory sticks out: whenever a fire truck passed, people on the street would stop and clap. The NYFD laid their lives on the line—many gave their lives—to help people stuck in the Towers. Each and every member deserved that applause. I was […]

The Compliance Defense Isn’t Dead…But It Should Be

It’s not often that I find myself disagreeing with two of the FCPA commentators I most respect, Tom Fox and Mike Volkov. It’s even rarer that I find myself disagreeing with Tom and Mike, and agreeing with another commentator who I respect immensely, but disagree with almost always, The FCPA Professor, Mike Koehler. Tom and […]

Upcoming Speaking Engagements

Women in eDiscovery, Philadelpha, May 9th ABA National Institute on Internal Investigations, San Francisco, May 16th Compliance Week, Washington, DC, June 4th Sedona Conference on Cross-Border Discovery & Data Privacy, Toronto, June 20-21 (Attending) AML & Anti-Corruption Roadshow, San Francisco, Houston, NYC, June 25, 26, 28

Completely Off Topic: I Hate My iPhone

Let me take a short break from anti-corruption and eDiscovery and just tell you that I hate my iPhone 4S. This should bother Apple. I am the guy who is so in love with his iPad that I actively promote its use among my friends and colleagues. I brag about its functionality. I relate how […]

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