Category: JPMorgan

Requiring The DOJ or SEC To Prove Its Case Is Not “Criminal”

It is truly a sorry state of affairs that have come to define government enforcement of criminal (or even civil) laws against business organizations.

Exhibit A is this recent CNBC video clip of Andrew Ross Sorkin’s interview of JPMorgan CEO Jamie Dimon.

As you likely know, JPMorgan recently resolved a variety of criminal and civil matters brought by various government enforcement agencies for approximately $20 billion.

“SORKIN: So, you look at these big numbers. And they are big numbers. And so the public looks at them and they are trying to grasp and understand what to make it. Do you think ultimately, that it was fair?

DIMON: No. I think a lot of it was unfair, but I’m not going to go into the details.”

No surprise there as the various JPMorgan resolution documents contained a so-called “muzzle clause.”  (See paragraph 17 of the JPMorgan DPA).

Dimon continued:

“And I’m grateful to have it behind us. Because the most important thing for a company is you do your job. Serving clients and communities around the world. And this is a huge negative for the company – a huge distraction of management time, board time, when we should really be helping our clients, which includes cities and schools. So we just wanted to get back, do what we’re good at and what we are supposed to be doing.”

The interview then continued as follows.

“SORKIN: On the stuff you think was wrong, do you think you fully remedied it?

DIMON: I guess at one point it doesn’t matter who you think is wrong or right, so we can debate all day long whether we should have paid. […] You know, again, you’re really caught between two bad choices. We made the one that was better for the company.

SORKIN: Right.

DIMON: Whether it should have been high or low, I don’t care anymore. I’ve moved on. That was last year. I’m looking forward to 2014.

SORKIN: One more question on that, which though is, was there a moment – what was the moment for you when you said to yourself, “ok. Pay it. I want to put this behind me.” And was there something that happened? Was it a conversation with the board? Was it a conversation with Eric Holder? What was that moment for you?

DIMON: First of all, the board was involved every step of the way in this. It was this kind of unprecedented, kind of – you know we have multiple regulators and multiple U.S. attorneys and district – Department of Justice. And it was just, thinking it through, looking at our options and realizing there are two really bad options. And that the wrong thing to do is to complain, fight and then you could have said, well why not go to court all those years? So if you are my board, you would have said, why would you do that and subject your company to three or four more years and the outcomes could be worse. Then wouldn’t even necessarily be better. So a lot of people said fight – if you think you are right, fight – banks have a very tough time doing that. It would really hurt this company and that would have been criminal for me to subject our company to that kind of – those kinds of issues.”

Obviously, one can assume that Dimon did not literally mean it was criminal to put the DOJ and/or SEC to its burden of proof.

However, the notion that an individual with fiduciary duties to a corporation and its shareholders would speak in those terms about something so basic and fundamental to the rule of law and our legal system is truly troubling.

But then again, can you blame Dimon?  He was perhaps simply acting consistent with those fiduciary duties and in the best interest of shareholders.   After all, should JPMorgan have put the DOJ (or SEC) to its burden of proof and thus been criminally indicted (or merely charged in a civil case) the hit to JPMorgan’s market capitalization (approximately $215 billion) likely would have been greater than $20 billion.  Viewed this way, the decision of JPMorgan’s board and it executives seems like a rationale corporate decision in the best interest of shareholders.

But here is the problem as I recently highlighted in my article “Why You Should Be Alarmed By the ADM FCPA Enforcement Action.”  While the specific risk-averse business decisions of a specific company may seem minor in isolation, the aggregate effect of these numerous decisions contributes to a facade of enforcement of any law – whether it is the Foreign Corrupt Practices Act (see here) or otherwise.

As former U.S. Attorney General Alberto Gonzales rightly noted in the FCPA context:

“In an ironic twist, the more that American companies elect to settle and not force the DOJ to defend its aggressive interpretation of the [FCPA], the more aggressive DOJ has become in its interpretation of the law and its prosecution decisions.”

For more on this dynamic see “Prosecutorial Common Law” by Michael Levy –  one of best guest posts in the history of FCPA Professor.

It truly is a sorry state of affairs.

And there is more.

As highlighted at the end of this video (around the five minute mark), Senator Elizabeth Warren chides government regulators for not exploiting this imbalance even more to extract even more shareholder money from risk averse corporations.

*****

The New York Times returns, once again, to JPMorgan’s FCPA scrutiny concerning alleged hiring practices in China.  This article states:

“[A] confidential email has emerged that shows a top Chinese regulator directly asked Jamie Dimon, the bank’s chief executive, for a “favor” to hire a young job applicant. The applicant, a family friend of the regulator, now works at JPMorgan.  […]  JPMorgan said Mr. Dimon had nothing to do with the decision to hire the young woman, described within the bank as well qualified. And like the C.E.O. of any large company, Mr. Dimon can be expected to meet with many people in a given day. According to a person briefed on the investigation, he is not suspected of any wrongdoing. Still, the episode underscores the dual forces driving JPMorgan and other Wall Street banks to hire the family and friends of China’s ruling elite. The banks sought to build good will with Chinese officials, who, in turn, expected favors from the banks.”

*****

Related to the above issue, this article states:

“UBS has suspended two staff members, including its top capital markets banker in Asia, as the Swiss bank investigates its hiring of the daughter [Joyce Wei] of the chairman of a Chinese chemicals company that is considering a $1 billion share sale the bank has sought a role in.  […]  Ms. Wei is the daughter of Wei Qi, the chairman of Tianhe Chemicals, a privately owned Chinese company that is considering a potential $1 billion initial public offering in Hong Kong this year. UBS is one of the banks positioned to secure a role in the deal.  […]  “It’s not a ‘princeling’ issue, because Joyce Wei is not a princeling,” [a person familar with the matter] said, referring to the children of senior Chinese government officials. “Tianhe is not a state-owned company,” the person added. Instead, the investigation is focused on “whether internal processes were adhered to or not.”

Even so, UBS remains part of the SEC’s industry sweep of the financial sector regarding hiring practices in China.

The U.S. Government Bears Some Responsibility

The U.S. government bears some responsibility when it comes to certain circumstances that result in FCPA scrutiny.  While some are likely to view this as a controversial statement or being a corporate apologist, this basic fact has always been relevant to the Foreign Corrupt Practices Act.

As highlighted in this prior post, one of the more insightful things found in the FCPA’s extensive legislative history is an October 1975 article by Milton Gwirtzman published by the New York Times Magazine.  At this point in time, Congress was in the midst of its investigations into the so-called foreign corporate payments problem and Gwirtzman noted:

“If corporate bribery abroad has offended the post-Watergate morality, the companies implicated have nevertheless taken a greater share of the blame than they deserve.  […]  The responsibility for present practices must also be shared by our Government,  which not only encouraged investment in countries whose ethical standards differ  from ours, but also in many respects set the pattern for the graft under censure today.  […]  The rapid acceleration of American private investment in foreign lands, which began in the mid-nineteen-sixties, was seen by our foreign policy makers as a welcome opportunity.  If U.S. firms could build a nation’s infrastructure, supply its consumer goods and hire a portion of its workers, the greater the likelihood the nation would be bound to ours by the safest and strongest of ties, economic self-interest.  As a result, our Government wrote the foreign investment laws of several developing countries and urged our multinationals to make use of them.  New programs were established to insure foreign investment against the risks of war and expropriation.  Embassy personnel were ordered to scout out export possibilities for American firms, which were published in Commerce Business Daily, the Government’s daily list of business opportunities.”

Gwirtzman then stated as follows.  “For all these reasons, it would be unwise, as well as unfair, simply to write off bribery abroad to corporate lust.  It is a symbol of far deeper issues that really involve America’s role in the world.”

In 2004, the U.S. government lifted various sanctions against Libya after Moammar Kadafi agreed to abandon a nuclear weapons program.  The White House encouraged “Libya’s reintegration with the global market” and a White House statement read:  “U.S. companies will be able to buy or invest in Libyan oil and products. U.S. commercial banks and other financial service providers will be able to participate in and support these transactions.”

The front-page article earlier this week in the Wall Street Journal read “Probe Widens Into Dealings Between Finance Firms, Libya.”  The article states, in pertinent part:

“The Justice Department has joined a widening investigation of banks, private-equity firms and hedge funds that may have violated antibribery laws in their dealings with Libya’s government-run investment fund, people familiar with the matter said. The criminal investigation, which has intensified in recent months, is proceeding alongside a civil probe by the Securities and Exchange Commission that began in 2011 and initially honed in on Goldman Sachs Group Inc. The Justice Department’s involvement hasn’t been reported previously. In addition to Goldman Sachs, federal investigators are examining Credit Suisse Group AG , J.P. Morgan Chase & Co., Société Générale SA, private-equity firm Blackstone Group LP and hedge-fund operator Och-Ziff Capital Management Group LLC, these people said. Spokesmen for the Justice Department and the SEC declined to comment.  Authorities are examining investment deals made around the time of the financial crisis and afterward, these people said. In the years leading up to Libya’s 2011 revolution, Western firms—encouraged by the U.S. government—raced to attract investment money from the North African nation, which was benefiting from oil sales and recently had opened to foreign investment. Investigators are trying to determine whether the firms violated the Foreign Corrupt Practices Act, the people said.

[…]

The U.S. lifted sanctions against Libya in 2004 in return for the country’s dismantling of its nuclear-weapons program. By 2008, as the financial crisis set in, Western firms were jockeying for business there. That year, then-Secretary of State Condoleezza Rice visited Libya and met with Col. Gadhafi in part to improve the investment climate there for U.S. companies, she said at the time. The government advised companies on investing in Libya, and U.S. executives went there on a government-sponsored trade mission in 2010.”

Whether its leading trade missions, providing export financing or provide support through diplomatic channels, in certain instances the U.S. government encourages companies (for foreign policy and other strategic interests) to go to the edge of the cliff.  As the passage of time occasionally shows, when the footing on the cliff becomes a bit loose, and the market participants fall over the edge, other segments of the U.S. government then launch a criminal inquiry seeking to discover why.

As I told a Foreign Policy reporter earlier this week in connection with the recent news:

“There is an irony of course in the U.S. government encouraging companies to do business in certain countries because it serves U.S. interests.  Then when the company does business in that country and encounters business conditions that the U.S. government no doubt knew it was going to encounter, the company then becomes the subject of a U.S. law enforcement inquiry.”

As so it goes.

If not before, I predict I will write about this issue again in the next few years when the DOJ and SEC launch an FCPA inquiry of various companies doing business in Myanmar.  In case you haven’t heard, the U.S. government recently eased various restrictions relevant to doing business in that country and is actively encouraging companies to toe the cliff.

Friday Roundup

What others are saying, more candy, seriously out-of-whack, not first hand, and for the reading stack.  It’s all here in the Friday Roundup.

What Others Are Saying

Last week, I published this article “Why You Should Be Alarmed By The ADM FCPA Enforcement Action.”  I’ve received a higher than norm amount of feedback – all positive – about the article via e-mail and social media.  Below is what others are saying about the article.

“For many reasons this is a terrific article.  [You are] very brave to write this necessary and timely analysis.”

“Just wanted to say thank you for keeping me updated on your FCPA-related work.  It looks like your 2010 Facade article is still holding up pretty well, despite the DOJ’s “Guidance” from last year.  It will be interesting to see how long the agencies can continue with their relatively unconstrained enforcement practices.”

Thanks for sharing Mike. And don’t change: you are as good as ever!

“Excellent article, Mike!  Readable even by those of us who are not lawyers.  The conclusion about why ADM chose settlement is undoubtedly true of many others who are charged, but leads to a question of the [conduct] of those who are charged to extract “easy takings” rather than have to justify themselves to the SEC or DOJ.  On whose behalf are they acting?”

Also a thank you for the many positive and encouraging comments I’ve received since publishing two posts (here and here) concerning the recent departure of the DOJ’s FCPA Unit Chief.

In other news on that front, White & Case recently announced here that Kathleen Hamann will join the firm as a partner “from the DOJ where she was an anticorruption policy counsel and trial lawyer assigned to the Foreign Corrupt Practices Act (FCPA) Team in the Criminal Division’s Fraud Section.”  The head of White & Case’s Global White Collar Practice stated: “Kathleen’s experience at the DOJ gives her a strong understanding of the complexities of the FCPA and the federal government’s anticorruption policies.  Kathleen is a wonderful addition to our global white collar team, and will further strengthen our ability to represent and defend clients around the world in all phases of investigations, and criminal and civil enforcement proceedings.”

More Candy

This previous post “Like a Kid In A Candy Store” highlighted the abundant offerings of FCPA year in reviews this time of year.

There is more candy to digest.

See here for the slick Global Bribery and Corruption Review 2013 from Hogan Lovells.

See here for Mayer Brown’s FCPA Update:  Year-End 2013.

But again, be warned – the divergent enforcement statistics are likely to make you dizzy at times and as to certain issues.  [Given the increase in FCPA Inc. statistical information and the growing interest in empirical FCPA-related research, I again highlight the need for an FCPA lingua franca (see here for the prior post), including adoption of the “core” approach to FCPA enforcement statistics (see here for the prior post), an approach endorsed by even the DOJ (see here), as well as commonly used by others outside the FCPA context (see here)]

Seriously Out-Of-Whack

One could have either of the following positions.

DOJ enforcement of criminal laws is more about leverage against public companies and risk aversion by corporate leaders rather than facts and law.  Therefore, even if a company settles various enforcement actions for approximately $20 billion in a year, it is not surprising that a company’s profits and stock price are up and that the company’s CEO is therefore given a substantial raise.

DOJ enforcement of criminal laws is about facts and law and if a company settles various enforcement actions for approximately $20 billion in a year, it is just not right that the company’s CEO is given a substantial raise.

Regardless of your position (I know where I fall), you would have to agree that things are seriously out-of-whack these days.

See here and here for articles regarding the compensation of James Dimon (CEO of JPMorgan).  As highlighted in the Wall Street Journal article.

“J.P. Morgan Chase’s board delivered a strong endorsement of Chief Executive James Dimon, boosting his pay 74% for a year in which the nation’s largest bank agreed to more than $20 billion in legal payouts …”  […] The raise reflects the view among the board that most shareholders believe Mr. Dimon is doing a good job protecting the bank’s earnings power and driving the stock price higher despite the high-profile legal settlements, according to people familiar with the board’s conversations. […] Many large shareholders seem comfortable with the bank’s leadership, too. The company’s stock price rose 33% during 2013, outpacing the 30% increase in the S&P 500 stock index. If not for its billions in legal expenses, J.P. Morgan likely would have earned record profits.  […]   Warren Buffett, the billionaire investor who personally owns an undisclosed number of shares in J.P. Morgan, described Mr. Dimon as a “bargain.” “If I owned J.P. Morgan Chase, he would be running it, and he would be making more money than the directors are paying him,” said Mr. Buffett, who has publicly defended the bank executive before.”

“Not First Hand”

JPMorgan of course is under FCPA scrutiny for its alleged hiring practices in China.  (See here among other posts).

In this video interview, Goldman Sach’s CEO Lloyd Blankfein talks about hiring issues at his company.  As noted in the related article, “asked whether he had seen any hiring that looked like a bribe, Mr. Blankfein paused for a moment” and said “not first hand.”

Reading Stack

From BalkanInsight, an in-depth piece regarding the Magyar Telecom enforcement action (see here for the prior post).

From the Economist regarding Brazil’s new FCPA-like law.

*****

A good weekend to all.

Friday Roundup

Did you notice?, scrutiny updates, quotable, too narrow, save the date and for the reading and viewing stack.  It’s all here in the Friday roundup.

Did You Notice?

This previous post – “Double Dipping” – spotlighted a common trend in issuer FCPA enforcement actions.  That is, the company pays twice for the improper conduct.  First, to the DOJ because alleged improper gain is a key factor in the advisory U.S. sentencing guidelines which guide criminal fine amounts, and again to the SEC because alleged improper gain often equates to a disgorgement amount.

Did you notice the following in the recent Alcoa enforcement action?  In the DOJ’s plea agreement with Alcoa World Alumina LLC the DOJ set forth various factors justifying a reduced criminal fine amount including:  “the significant remedy being imposed on the Defendant’s majority shareholder, Alcoa, by the U.S. Securities and Exchange Commission for Alcoa’s conduct in this matter.”

FCPA practitioners would be wise to file this someplace important and the DOJ’s recognition of such “double-dipping” is a welcome development.  Time will tell whether it was case specific.

Scrutiny Updates

Companies have different disclosure practices.  Some companies disclose specific FCPA internal investigation costs, others do not.  When a company falls into the former category, it is a relevant datapoint.  Nordion (see this prior post for its initial disclosure) recently disclosed that its “full year expenses associated with [its] investigation was $11.8 million.”

Microsoft, which first became the subject of FCPA scrutiny in March 2013 (see here) – thereby exposing the fallacy of the “good companies, don’t bribe period” position (see here) –  “is now requiring its partners to educate their employees on the legal
consequences of bribery and other illegal activity.”  So says this recent article in CRN which further states:   “A new Microsoft partner program requirement that went into effect this month calls for partners to “provide anti-corruption training to all employees who resell, distribute, or market Microsoft products or services,” Microsoft said in a document sent recently to partners, which was viewed by CRN.”

Quotable

Homer Moyer (Miller & Chevalier and a dean of the FCPA) steps up to the plate and hits another one out of the park.  In this recent article he states:

“One reality is the [FCPA] enforcement agencies’ views on issues and enforcement policies, positions on which they are rarely challenged in court.  The other is what knowledgeable counsel believe the government could sustain in court, should their interpretations or positions be challenged.  The two may not be the same.  The operative rules of the game are the agencies’ views unless a company is prepared to go to court or to mount a serious challenge within the agencies.”

Spot-on.

While the decision of one risk-averse business organization to settle an FCPA enforcement action may seem case specific, the long-term effects of such a decision affect not only the settling company, but other business organizations subject to increasingly aggressive FCPA enforcement theories.  (See here for a previous guest post titled “Prosecutorial Common Law”).

As former Attorney General Alberto Gonzales rightly noted:

“In an ironic twist, the more that American companies elect to settle and not force the DOJ to defend its aggressive interpretation of the [FCPA], the more aggressive DOJ has become in its interpretation of the law and its prosecution decisions.”

Friday Roundup

Scrutiny alerts and updates, sunshine, year in review roundups, and for the reading stack.  It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

H-P

The company has been under FCPA scrutiny since at least 2010 and recently disclosed, in pertinent part, as follows.

“The U.S. Department of Justice and the SEC have been conducting an investigation into the Russia GPO deal and potential violations of the Foreign Corrupt Practices Act (“FCPA”). These U.S. enforcement agencies, as well as the Polish Central Anti-Corruption Bureau, are also conducting investigations into potential FCPA violations by an employee of Hewlett-Packard Polska Sp. z o.o., an indirect subsidiary of HP, in connection with certain public-sector transactions in Poland. In addition, the same U.S. enforcement agencies are conducting investigations into certain other public-sector transactions in Russia, Poland, the Commonwealth of Independent States, and Mexico, among other countries.  HP is cooperating with these investigating agencies. In addition, HP is in advanced discussions with the U.S. enforcement agencies to resolve their investigations.”

JPMorgan

The New York Times returned – yet again (see here and here for prior NY Times article) – to JPMorgan’s hiring practices in China.  The article states:

“For Wall Street banks enduring slowdowns in the wake of the financial crisis, China was the last great gold rush. As its economy boomed, China’s state-owned enterprises were using banks to raise billions of dollars in stock and debt offerings — yet JPMorgan was falling further behind in capturing that business.  The solution, the executives decided over email, was to embrace the strategy that seemed to work so well for rivals: hire the children of China’s ruling elite.

[…]

In the months and years that followed, emails and other confidential documents show, JPMorgan escalated what it called its “Sons and Daughters” hiring program, adding scores of well-connected employees and tracking how those hires translated into business deals with the Chinese government. The previously unreported emails and documents — copies of which were reviewed by The New York Times — offer a view into JPMorgan’s motivations for ramping up the hiring program, suggesting that competitive pressures drove many of the bank’s decisions that are now under federal investigation.

The references to other banks in the emails also paint for the first time a broad picture of questionable hiring practices by other Wall Street banks doing business in China — some of them hiring the same employees with family connections. Since opening a bribery investigation into JPMorgan this spring, the authorities have expanded the inquiry to include hiring at other big banks. Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs and Morgan Stanley have previously been identified as coming under scrutiny. A sixth bank, UBS, is also facing scrutiny, according to interviews with current and former Wall Street employees.

[…]

The investigation has also had a chilling effect on JPMorgan’s deal-making in China, interviews show. The bank, seeking to build good will with federal authorities, has considered forgoing certain deals in China and abandoned one assignment altogether.”

Once again, the latest NY Times article sparked much commentary.  See here, here and here.

Former Siemens Executives

The Buenos Aires Herald reports:

“Seventeen people, including former managers of the Siemens company, were … accused of paying off officials in order to help win a contract to produce the national identity cards …”.  The decision was made by Federal Judge Ariel Lijo, who decided to indict them for having allegedly committed bribery.”

Regarding the defendants, the article states:

“Twelve people working for Siemens were included in the indictment: Uriel Jonathan Sharef, Ulrich Albert Otto Fritz Bock, Eberhard George Reichert, Luis Rodolfo Schirado, Andrés Ricardo Truppel, Ernst Michael Brechtel, Bernd Regendatz, Ralph Matthias Kleinhempel and José Alberto Ares. Sharef, for instance, was a member of Siemens’ managing board. He also was the first former board member of a Fortune Global 50 company to be indicted under the US Foreign Corrupt Practices Act, as happened in 2011.  Judge Lijo also charged Carlos Francisco Soriano, Miguel Ángel Czysch and José Antonio David as “middlemen” between the company and Menem’s administration to arrange the payment for benefitting the company in the bid. The magistrate also accused Antonio Justo Solsona, Guillermo Andrés Romero, Orlando Salvestrini, Luis Guillermo Cudmani and Federico Rossi Beguy, who allegedly worked for the company competing in the bid against Siemens IT Services and who presumably agreed not to challenge the government’s decision.”

Allegations regarding the Argentine identity card project were included in the 2008 FCPA enforcement action against Siemens (see here) and also served as the basis for 2011 criminal and civil charges against several former Siemens executives, including those recently charged in Argentina (see here for the prior post summarizing the action).

As noted in this previous post, the U.S. charges against the former Siemens executives were brought after the DOJ faced scrutiny (including at the Senate’s 2010 FCPA hearing) for not bringing any individual enforcement action in connection with a bribery scheme “unprecedented in scale and geographic reach” in which there existed at Siemens a “corporate culture in which bribery was tolerated and even rewarded at the highest levels of the company.”

The U.S. criminal charges against former Siemens executives sits on the docket and a recent docket search indicates that there has not been any activity in the case in over two years.

Sunshine

Mark Cuban, who recently prevailed against the SEC in a long-running insider trading enforcement action, says in this Wall Street Journal article that he is “now considering a new venture publicizing SEC transcripts.”  Says Cuban, “I’m going to get as many as I can, and I’ll put it out there.” “Sunshine is the best disinfectant.”

The article further states:

“Mr. Cuban says he isn’t against the SEC as a whole but thinks that the lawyers who work there should be held responsible for their actions. “There’s such a revolving door, and it was run by attorneys with an attorney’s mind-set looking for their next job,” he says. “It’s a résumé builder.” Mr. Cuban says individual lawyers aren’t held accountable because the public is familiar only with the name of the SEC’s chair, Mary Jo White.  “No wonder they say or do whatever they damn well please,” he says. “I’m like, ‘OK, I’m going to start calling them out by name.’  George Canellos, co-director of the SEC’s enforcement division, sent a response to Mr. Cuban’s statements through an SEC spokesperson: “Mr. Cuban’s comments are without merit and uncalled for. Our lawyers acted in the finest traditions of government counsel and entirely appropriately in strongly advocating the position of the government in this matter.”

On a related note, did you know that the FCPA Professor Scribd page contains approximately 250 hard to find FCPA documents, pleadings, briefs, etc.

Year In Review Roundups

From the Wall Street Journal Risk & Compliance Journal page – a “Q&A with Asheesh Goel, Ropes & Gray, on The Year in FCPA“

From Trace Blog – “FCPA Corporate Settlements by the Numbers“

From Michael Volkov (Corruption, Crime & Compliance) – “The FCPA Person of the Year – The Prosecutor” and “FCPA Predictions for the New Year – 2014“

From Thomas Fox (FCPA Compliance and Ethics Blog) – “My Favorite Blog Posts from 2013“

Reading Stack

Thomas Fox (FCPA Compliance and Ethics Blog) and Jon Rydberg (Orchid Advisor) are out with a new book here titled “Anti-Bribery Leadership: Practical FCPA and U.K Bribery Act Compliance Concepts for the Corporate Board Member, C-Suite Executive and General Counsel.”

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A good weekend to all.