UK Bribery Act – Howard@OpenAir

Howard@OpenAir

UK Bribery Act

“The Limit Should Be Zero Dollars”

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.

“Luncheon Law” and a Lesson from the Professor

Let me start by saying that I disagree with Prof. Mike Koehler about 95% of the time. That’s not to say he’s wrong; he rarely is. It’s just that he and I have widely disparate views on enforcement, and we read the same facts in different ways. Because of that, we almost invariably come to […]

If I Were a Law Firm Managing Partner

I’ve never worked at a law firm. Never. It’s an unusual path to take as a lawyer, I admit. I worked as a research assistant for professors during my summers, and interned at the DOJ. I became a prosecutor, then a regulator, then went in-house. So of course I’m the perfect person to give advice […]

Who is Hughes Hubbard?

That’s not a serious question; everyone knows it’s a good firm. It’s been around for a while (the latter part of the 1800s). The White Collar & Compliance team isn’t that big: about 30 lawyers come up when you search under that practice group firm-wide. And I don’t think it’s particularly well-known in the FCPA […]

Guidance By Howard

After finishing the case study series, I now turn to keeping my word and writing my own Guidance. Rather than try to write the whole thing at one fell swoop, I will write it section by section, and publish as I write. I’ve tried to make it humorous, but readable. And while it is written […]

Case Study #11: I Open at the Close

My kids are reading Harry Potter, which is where the title comes from. Given Harry’s UK origins, I thought it appropriate. I’m also a little worried because I’m coming to the UK next week. I’ve been, ahem, somewhat critical of the UK government recently, and I’d like to be admitted to that wonderful country. So […]

Case Study #10: Tone Deaf

I had thought that with the amount of bile I’ve spewed on these case studies, my supply must be low. I’ve found, reading case study #10, that I actually have plenty left. The case study purports to discuss what we call in the US “tone at the top,” but which in the UK they call […]

Case Study #9: Everything Old is New Again

Case Study #9: Everything Old is New Again I’m having a bad case of vu-ja-day. Not deja-vu, Vuja-day. It’s the feeling that you really didn’t want this to happen again. Case study #9 is a return to due diligence of agents. I’ll go through it point by point, but let me give away the ending: […]

What to Do About the UK Bribery Act

This past week, I was on a webinar with Mark Mendelsohn (the replay can be found here: http://bit.ly/gTAeKB). One of the things we spoke about was what companies need to do now to comply. I was a little more sanguine than Mark was; I thought that we should wait and see whether the UK actually […]

Case Study #7: Needed–Training…on how to write an effective case study.

Case Study #7: Communication and Training I find it somewhat interesting that the case study calls it “Communication and Training” while the Principle (#5) calls it “Communication (including training)”. OK, I don’t find it particularly interesting, but it must mean something. I find them to be two distinct issues. Training is training. Communication, however, should […]

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