Walking my dog the other day, I passed a “drug-free zone” sign and, smelling marijuana, smiled at the three guys standing there passing a joint. (Even with the new DC marijuana laws you still can’t light up on the streets, especially in front of the drug-free school zone.) The three guys were not just standing…

Lawyers, particularly prosecutors, love to question people and then to cross-examine about inconsistent answers to the questions. This compulsion to ask questions is acute in prosecutors because their job is to get to the bottom of things. The counterweight to this is the defense instinct to rebuff questions by “lawyering-up”, asserting the Fifth Amendment or…

Entering a relationship with a new client, sales consultant, joint venture partner, or any other entity merits thoughtful consideration to protect your business’ value. Likewise, once you enter a relationship, you need to make sure the relationship stays healthy and productive over time. This is especially true when working with governments or doing business internationally…

Former Defense Secretary Donald Rumsfeld, when speaking about the Iraq War, took a lot of “writ” for saying there are unknown unknowns and that the unknown unknowns are difficult to manage. No doubt it is a weird statement on its face. But, most folks who manage risk for a living understand that the unknown unknowns…

FOCI – Foreign Ownership, Control and Interest Given the information and technology that U.S. defense contractors have and the role they play in U.S national security, U.S. defense contractors need to be particularly concerned about the dangers of the world. To manage the wild and dangerous world, regulations, particularly those detailed in the National Industrial…

“Oh baby, baby, it’s a wild world.” -Yusuf Islam, formerly known as Cat Stevens To assist businesses in operating in this wild world, the U.S. government tries to pass laws that it thinks will protect businesses and U.S. national security. The Foreign Agent Registration Act (22 U.S.C. 611 et seq.; 28 CFR Part 5) (FARA)…

Whether your organization is building an anti-corruption program from scratch, or improving an existing one, it can be an intimidating, time-consuming and costly process. Either way, thinking about an anti-corruption program strategically and holistically can build efficiencies and effectiveness. A holistic approach to an anti-corruption program allows leadership to provide strategic direction and to actually…

Given my practice area, people often ask me why people commit white-collar crimes. I ask myself this question; and, just as often, I ask myself how can I help my corporate clients mitigate the risks of committing a crime? Despite my lifelong quest to answer both these questions, I have no good answers. Unfortunately, the…

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