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It’s A Foreign Corrupt Practices Act World


The Foreign Corrupt Practices Act was once viewed as “little more than a policy assertion” and a “very difficult if not impossible” law to enforce.

However, the FCPA has ensnarled a wide range of companies that offer products and services that impact and/or improve our daily lives.

In recognition of the FCPA’s 40th anniversary, the over 200 companies that have resolved FCPA enforcement actions are weaved into a fictional story to demonstrate that it truly is a Foreign Corrupt Practices Act world!

My Phillips Electronics alarm clock went off at 4:45 a.m. and it was going to be a long day. Because my alarm clock is linked to Nortek’s Smart Home system, most of the lights in my house also went one, the blinds were raised, and the temperature in the house rose taking away the chill of the early morning.

Although up a bit earlier than normal, I stuck to my morning routine which begins with a glass of crisp clear water thanks to my Watts Water Technologies filtration system. The hipster that I am, I drink the water from glass canning jars manufactured by Ball Corporation, one of my prized possessions given to me by Aunt Carol who enjoyed a comfortable life as the local “Avon lady” selling cosmetics and beauty products.

I next turned on my IBM computer (an oldie but goodie) to browse the morning business news and saw that Braskem, a unit of Odebrecht, has developed a Green Plastic made of sugarcane.  I had some work to get done before my busy day, but thankfully my suite of products from Oracle and SAP allow me to be efficient in my work. I have a report due later this week on TechnipFMC, a company involved in oil and gas projects, thus I reviewed the Dunn & Bradstreet report on the company and printed it out on my HP OfficeJet printer. I used the information to draft a portion of my report and saved it on the cloud through a security product sold by Akamai Technologies because I was traveling later in the day.

The baby’s morning cry shattered the silence of an otherwise productive morning and I fetched the bottle filed with Enfamil sold by Mead Johnson. After feeding Junior, I sprinkled him with Johnson & Johnson’s baby powder and he went back to sleep.

It was time for breakfast, the most important meal of the day, and the menu included Chiquita bananas, Jimmy Dean breakfast sausages produced by Tyson Foods, and glass of milk fortified with products sold by Vitusa. I saved the final swig of milk to down my vitamin supplements sold by Nature’s Sunshine Products as well as my morning pills produced by Eli Lilly and Novartis. Thankfully, one additional pill cost less because it is a generic sold by Teva Pharmaceuticals. After my morning shower, I applied some Nu Skin anti-aging cream to my face and decided to wear my favorite Ralph Lauren polo shirt for the day ahead.

I glanced at my cell phone, powered by a Qualcomm SDM450 Processor, and gosh it was already 6:30 a.m. and I had a long day ahead of me before my 7 p.m. flight to Las Vegas to celebrate my friend’s 40th birthday. Before leaving the house, I fed the dog and applied Vet’s Best flea and tick spray on her, a product of NCH’s retail products group.

Because I would be away for a few days, I walked over to Grandma and Grandpa’s house to make sure their pill boxes were properly filled. As usual, they weren’t so I opened the medicine cabinet and good lord it’s like they had a pharmacy in their house with products from Bristol Myers Squibb, Immucor, Novo Nordisk, Sanofi, Schering Plough, SciClone Pharmaceuticals and Wyeth. Just as I was about to close the medicine cabinet, I saw something I wish I could forget. There it was, Grandpa’s bottle of Viagra manufactured by Pfizer and there were only two tablets left!

It’s all good though and one can never take grandparents for granted. Indeed, Grandma suffered a stroke about ten years ago, but is doing well after the neurosurgeon used various Micrus coil devices and stents to patch her up. Still, once a year Grandma needs to have tests performed using equipment provided by InSightec, a division of Elbit Imaging. And then there was Grandma’s recent fall that left her with several broken bones, but after her spinal fusion using Stryker products and her new Galaxy wrist by Orthofix International, she is in good spirts.

Grandpa has had his share of medical mishaps as well. Given his love of cheese and sausage, it was no surprise that he had heart problems, but thanks to some legacy AGA Medical products his ticker keeps on doing its job. While in the hospital for his heart problems, Grandpa’s blood was tested using various products produced by Bio-Rad. And then there was Grandpa’s hip replacement surgery using a Smith & Nephew product. As a result, he does not get around well in the yard so when he asked me to kill a few weeds in his garden using Roundup manufactured by Monsanto, I was happy to help. Before leaving their house, I rewarded myself by snatching some Oreo Cookies by Mondelēz International from Grandma’s cookie jar.

After leaving the grandparents, I hopped into my Fiat 500 automobile equipped with Bridgestone tires and turned on the car radio. One of my favorite songs – International Harvester by Craig Morgan – was playing and the song reminded me of Uncle Glen, even though his tractor was actually manufactured by AGCO. Being ahead of schedule, I decided to stop by Uncle Glen’s farm. He has been through a lot lately with his liver cancer diagnosis, but seems to be responding well to TheraSphere therapy provided by Nordion. Driving down the long gravel road to his house, I passed by several crops boosted by SQM fertilizer.

Uncle Glen and I had a good visit and as usual he told me some stories about his younger years when he raced horses. I asked him about his most memorable race and, without hesitation, he told me about the time he raced at the Caroni Racetrack in Trinidad built by Sam Wallace Company Inc. and how the totalisator system by American Totalisator Co. failed resulting in many disgruntled wagers. After listening to Uncle Glen’s story, he showed me the still shining medal he won at the race with gold produced by BHP Billiton.

Next, Uncle Glen invited me to walk around the property and he told me how he recently switched to tobacco farming. Sure enough, there in the old barn were tobacco leaves hanging from the rafters and Uncle Glen explained he was under contract to sell them to Alliance One International and Universal Corporation. In the barn there were also old seeds from Delta & Pine Land Company from when Uncle Glen used to plant cotton, old Goodyear tires, bulk copper cable from General Cable, insecticide from Dow Chemical, compression equipment from Crawford Enterprises, turbines from Ruston Gas, and his prized Smith & Wesson 686 revolver. After a barn fire a few years ago, I was happy to see that Uncle Glen had a few Tyco manufactured fire extinguishers in the barn as well.

It was great to see Uncle Glen and before leaving his house he asked me to touch up some blemishes on his kitchen wall so I grabbed the bucket of Azko Nobel manufactured paint and got the job done. I then told Uncle Glen that I needed to stay on schedule because of my evening flight to Las Vegas and when he smiled his signature gold tooth (perhaps it was Kinross Gold) was visible and he reminisced about his first flight in the late 1970’s on Page Airlines.

After leaving Uncle Glen, I made a quick stop at my local JPMorgan bank and withdrew $500 for the trip from a Diebold manufactured cash dispenser. While at the bank, I remembered that I had a few questions for my financial advisor so I popped into Brad’s office to see how my investments were doing. Brad explained that my investments in several funds managed by Legg Mason, Och-Ziff, Omega Advisors and Societe Generale were doing well. As financial advisors are sometimes apt to do, Brad also tried to cross sell various insurance products offered by Aon, Allianz and even the Insurance Company of Barbados. However, I respectfully declined.

When I got back to the car, I noticed I was nearly empty on gas so I pulled into the Chevron gas station to fill up. While at the gas station, I had a most interesting conversation with Bill, a gas tanker truck driver, who explained in detail how oil and gas get from the ground into my car.

It all starts, Bill told me, with exploration and production companies such as ENI, Royal Dutch Shell, Statoil, Total, Petrobras (and years ago Katy Industries, Triton Energy, Tesoro Petroleum, C.E. Miller, and Applied Process Products Overseas) looking for that “black gold” beneath the earth’s surface. Those companies of course need help looking for the good stuff and in this day and age use sophisticated software developed by companies such as Paradigm. Often times the good stuff is found offshore deep beneath the ocean meaning that offshore drilling and services companies such as Noble Corp., Transocean, SBM Offshore, Halliburton, and Oil States International play a key role. In fact, Bill explained, there are also companies such as GlobalSantaFe, Tidewater, and Keppel Offshore that specialize in building vessels, ships and other rigs used in oil exploration. Bill also said that it takes real people to work on the offshore oil rigs and companies such as Bristow Group provide transportation services to get workers on and off the offshore production facilities. Whether on land or water, Bill then explained that the “black gold” doesn’t exactly float to the surface but pumps, valves, and other drilling equipment and services produced or provided by companies such as Baker Hughes, BJ Services, Aibel Group, NATCO Group, International Systems & Controls, Helmerich & Payne, Parking Drilling, and Pride International aid in the effort to make oil production time and cost efficient.

All the while, Bill said, trained professionals monitor flow measurements with equipment provided by companies such as Saybolt, Weatherford International and Flowserve which offers a suite of products to improve the reliability and efficiency of engineers and other professionals. Bill explained that the oil of course doesn’t just stay at the production facility, but needs to be moved through pipelines provided by companies like Willbros, and then sent to refineries such as the Ashland Oil refinery he used to work at years ago, and then stored in large storage tanks such as those produced by HMT. As to the gas in his tanker truck, Bill explained that not all gas is equal and that specialty chemical companies such as Innospec use their fuel additive knowledge and technology allowing different types of gas to find their way to market.

Who knew a trip to the gas station could be so enlightening and I will never forget Bill’s informative tutorial on oil and gas production. However, it made me hungry so I stopped into the convenience store attached to the gas station and picked up some organic dried fruits offered by Archers Daniels Midland Company – you’ve probably heard their slogan “supermarket to the world.” I also placed on the counter two oranges which arrived to the U.S. via Panalpina’s perishables network which provides temperature controlled freight services. I paid for the gas and snacks with my credit card confident that the transaction would be secure because of the hologram by American Bank Note Holographics incorporated into the card.

Back on the road, I was stuck behind a slow-moving Con-Way freight tractor-trailer which must have been slowed down by its heavy load of diagnostic testing machines originally developed by Alere. Along the highway, I saw a freight train powered by the Vectron locomotive series made by Siemens and equipped with brakes manufactured by Wabtec Corporation. As I was driving, I received a call from my neighbor Sarah who works at a nearby nuclear power plant. Sarah has long known of my interest in nuclear power and today was my lucky day to tour the facility.

Not surprisingly, when I arrived to the entrance of the plant it was patrolled by security guards who wore ballistic resistant vests originally manufactured by Armor Holdings and were also equipped with night-vision goggles manufactured by FLIR Systems. The guards told me I better follow all the rules inside the power plant because it was tied into the Department of Homeland Security via communication products originally produced by Titan Corp.

Before entering the functional portion of the plant, Sarah handed me the RAE Systems DoseRAE Pro radiation measuring device that I was required to wear and, as backup, Sarah had a Maxwell Technologies HSN-1000 Nuclear Event Detector.

Sarah began the tour by describing the history of the plant and how the design and construction was overseen by JGC Corp. with assistance from Bilfinger. She further explained how Schnitzer Steel Industries provided high-quality rebar in connection with the construction and Tenaris provided seamless tubes and pipes in different steel grades for various power generation applications.

There is a lot that goes into running a nuclear power plant and Sarah explained that ITT’s Dia-Flo diaphragm valves and Cam-Tite ball valves are used in the reactor and valves from Control Components are used elsewhere in the plant. Instrumentation and controls originally supplied by Data Systems & Solutions and fire-stop penetration seals originally manufactured by Silicon Contractors are also incorporated into the power plant as are Ingersoll-Rand manufactured hoists, winches and support structures to assist in safe and efficient movement of structures within the plant. Sarah further explained that Linde supplies high-purity oxygen that is used in the nuclear reactors, that Faro Technologies’ Focus3D X 130 laser scanner is used in connection with plant inspections, and that PTC’s Windchill FRACAS (failure reporting, analysis, and corrective action system) communication framework is used to collect and report on incidents. Finally, Sarah explained that the power plant has a contract with Transport Logistics International for front and back end nuclear fuel transportation needs.

The tour was so interesting I almost forgot that I had a flight to catch so I checked the airline check-in application on my phone, a legacy product of Veraz Networks, and got back into the car to head to the airport. After about an hour in the car, I arrived to the airport and parked in the cheap remote parking lot  next to a National Guard flight operations center supported by IAP Worldwide Services. I boarded a bus manufactured by AB Volvo and was transported to the terminal. While on the bus, I struck up a conversation with the driver and she said she used to work for El Paso Corporation, a national gas producer, but left the company because she really enjoys driving and interacting with people. I told her I liked the comfort of the bus and she said that it was much better than the old bus from Eagle Bus Manufacturing that she used to drive.

I arrived to the airport terminal, a beautiful facility designed by Louis Berger using Alcoa steel. With the assistance of CDM Smith, the airport has a sustainability performance improvement management system, Wi-Fi thanks to the Carrier Wi-Fi product line of UTStarcom, and an integrated communication systems provided by Alcatel-Lucent to minimize the risk of a cyber-attack on the airport’s network infrastructure.

While standing in line at the ticket counter, I struck up a conversation with a dental student who was engaged in research employing Bruker’s microCT to analyze dental and associated bone tissues. In furtherance of his education, he was traveling to Palm Beach Gardens, Florida to visit the Zimmer Biomet Dental campus to see how dental implants were made. I asked how he liked the dental field and he said much better compared to his prior jobs at Diagnostic Products Corp. selling automated body fluid analyzers and Syncor International selling radiopharmaceutical products.

Prior to checking my baggage, I transferred my Olympus Pen camera to my backpack and then checked my baggage and saw it pass through an InVision detection system on its way to the airplane. Next up was gate security, but this process went smoothly thanks to Analogic’s ConnectCT screening solution for airports which allows passengers to keep their personal electronic devices in their bags significantly reducing the need for time-consuming secondary inspections.

I boarded the Embraer manufactured jet which had a Panasonic Avionics Cabin Management System enabling the cabin crew to control the entire inflight experience. The airplane seemed to be in good shape thanks to the thrust reverser overhaul recently performed by NORDAM Group as well as the turbine engine overhaul recently performed by Dallas Airmotive.

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I settled into my window seat and saw several private jets being serviced by BizJet International which offers full service FBO services such as fueling, customer and pilot lounges, conference rooms, wireless internet, and concierge services. A few minutes later, I struck up a conversation with Melissa who was seated next to me and headed to Las Vegas for a telecommunications convention in the hopes of finding a job. She explained her bad luck working for now defunct companies Cinergy Telecommunications, Latin Node, Comverse Technology, and Nexus Technologies but was optimistic about finding a job at the convention because companies from around the world such as Magyar Telecom, Telia, and Vimpelcom would be in attendance.

I always enjoy flying to see the land and structures below me. From my window seat, I saw a sewage and wastewater treatment facility originally serviced by Metcalf & Eddy and further designed and enhanced by The PBSJ Corp. a company that provided engineering, planning and construction management services. I saw a beef processing plant recently acquired by Marubeni Corporation and also saw traffic flow smoothly through a mountainous city thanks in part to the city partnering with Hitachi on a community-wide camera system to deliver better traffic flow through city intersections and faster and more accurate emergency response. I also flew over a barren desert community whose water supply was met thanks to a drilling project overseen by Layne Christensen Company.

It had been a long day already and I must have taken a quick nap complete with a strange dream. I was in the Cook Islands on behalf of Kenny International running the country’s philatelic bureau and a young Ross Perot comes into the office telling me how he recently incorporated Electronic Data Systems. A short time later, we drove to a warehouse on the edge of town where United Industrial Corp. was secretly running a training program for the U.S. Department of Defense and in the warehouse there was an abundance of surplus military equipment previously owned by International Materials Solutions, Controls Systems Specialists, International Materials Solutions, and UNC/Lear Services. NAPCO International, a company that services military aircraft, was also operating out of the warehouse and I witnessed an Israeli Air Force officer arrive for flight training using a system supplied by W.S. Kirkpatrick. Because the anti-bugging devices supplied by F.G. Mason Engineering to detect the presence of electronic surveillance failed, a conversation was recorded between a General Electric representative and the Israeli Air Force officer to divert military aid for their personal use and other unauthorized purposes. The Israeli Air Force officer felt his conduct was justified because Lockheed hired an Egyptian foreign official as a consultant to use her position to influence the government to purchase aircraft from Lockheed. I was shocked by what I saw and hear and ran from the warehouse to the nearest Bell South pay phone to call law enforcement.

I was awoken from my strange dream as the flight began its initial descent into Las Vegas and as we approached the airport, I could see the lights of Las Vegas. The utility providing the power for the lights uses Alstom’s latest Demand Response Management System to direct load controls and other applications.

After my flight landed, the plan was for me to wait for my other buddies to arrive. My college friend Jim, who moved to Chile a few years ago was flying in aboard a LATAM Airlines flight and my other friend Brent, who moved to Europe a few years ago for a job in the investment banking division of Credit Suisse, was flying in aboard at Lufthansa flight. To pass the time, I walked around the airport and saw many advertisements placed by advertising agency Young & Rubicam. I saw ads for BNY Mellon, a banking and financial services company, and KPMG, a professional services firm offering audit, tax and advisory services.

Once everyone arrived, we proceeded to baggage claim and all bags arrived thanks to the automated system manufactured by Rockwell Automation, not to mention the overall power efficiency at the airport due to the recently installed ABB system.

Given the special occasion, we hired a private driver who picked us up at the airport in a Rolls-Royce Phantom V Limousine before dropping us off at the Venetian Hotel operated by Las Vegas Sands Corporation. After checking in, we took the Otis elevator manufactured by a unit of United Technologies to the top floor penthouse suite. It was extremely warm in the room so I adjusted the Johnson Controls wall mount temperature control panel and the York air-conditioning unit kicked up. We purchased a special “high-roller” package which meant that drinks were on the house while we gambled and there were samplings from Beam, ABInBev, and Diageo. After becoming a bit more courageous we ended the evening with a helicopter ride over the Las Vegas Strip in a Bell 206 helicopter manufactured by a unit of Textron.

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