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The Certainty of Donald Rumsfeld (Part 1) Four kinds of persons: zeal without knowledge; knowledge without zeal; neither knowledge nor zeal; both zeal and knowledge. When I first met Donald Rumsfeld in his offices in Washington, D.C., one of the things I said to him was that if we could provide an answer to the American public about why we went to war in Iraq, we would be rendering an writing college essays Northfield, important service. He agreed. Unfortunately, after having spent 33 hours over the course of a year interviewing Mr. Rumsfeld, I fear I know less about the origins of the Iraq war than when I started. Argue Essay Kendall College? A question presents itself: How could that be? How could I know less rather than more? Was he hiding something? Or was there really little more than met the eye? Jack McWethy, the ABC Pentagon correspondent, asked Rumsfeld about the for money Northfield Mount Hermon, containment policies of the Clinton administration.[1]

The substance of argue essay College, Rumsfeld’s reply reiterated his previous condemnations of essays Mount, those policies — sanctions aren’t working, the no-fly zones produce little or no benefit, and research paper sites Queen School Saddam is developing weapons of mass destruction.[2] It was also a warning: DONALD RUMSFELD: Every year that goes by and the essays Northfield Mount Hermon, inspectors are not there, the paper Queen School, development of their weapons of mass destruction proceed apace, bringing them closer to writing for money Hermon a time when they will have those weapons developed in texas republican thinking International School of Milan a form that is more threatening than it had been the year before or the year before that. Jim Miklaszewski, the NBC Pentagon correspondent, asked another question. JIM MIKLASZEWSKI: In regard to Iraq weapons of mass destruction and writing for money terrorists, is there any evidence to indicate that Iraq has attempted to an essay about College or is willing to supply terrorists with weapons of mass destruction? Because there are reports that there is no evidence of a direct link between Baghdad and some of writing college essays Mount, these terrorist organizations. DONALD RUMSFELD: Reports that say that something hasn’t happened are always interesting to me, because as we know, there are known knowns; there are things we know we know. We also know there are known unknowns; that is to say we know there are some things we do not know. But there are also unknown unknowns — the ones we don’t know we don’t know. And if one looks throughout the what journal, history of writing essays for money Hermon, our country and other free countries, it is the write article Taunton School, latter category that tend to writing for money Mount Hermon be the difficult ones. And so people who have the omniscience that they can say with high certainty that something has not happened or is not being tried, have capabilities that are — what was the word you used, Pam, earlier? PAM HESS: Free associate.[3] [The phrase “free associate” came earlier in the press conference in response to a question about drones.]

DONALD RUMSFELD: Yeah. They can do things I can’t do. (laughter) Few people today remember that Rumsfeld was ostensibly responding to Miklaszewski’s request for evidence . What evidence do you have that Iraq is steps for writing a persuasive essay supplying terrorists with W.M.D.? Rumsfeld’s answer was a non-answer — not just an evasion or a misdirection. Many people believe Rumsfeld’s reply was brilliant. I think otherwise. Miklaszewski was unsatisfied and was trying to pin him down. I sense his frustration. I share it.

What is college for money Mount he saying? Miklaszewski continued: JIM MIKLASZEWSKI: Excuse me. But is this an unknown unknown? JIM MIKLASZEWSKI: Because you said several unknowns, and I’m just wondering if this is an unknown unknown. DONALD RUMSFELD: I’m not going to say which it is. Jamie McIntyre, the paper sites, senior Pentagon correspondent for CNN, returned to the real question — the question of evidence . JAMIE McINTYRE: I just want to — because you so cleverly buried Jim Miklaszewski’s question by characterizing it as something that was unknowable. College For Money? But he didn’t ask you [about] something that was unknowable. He asked you if you knew of research School, evidence that Iraq was supplying — or willing to supply weapons of college Mount Hermon, mass destruction to terrorists — DONALD RUMSFELD: He cited reports where people said that was not the case. JAMIE McINTYRE: Right.

He’s done that and — DONALD RUMSFELD: And my response was to sites School that, and writing for money Northfield Mount I thought it was good response. But McIntyre did not give up. And Rumsfeld slipped into more gobbledygook. JAMIE McINTYRE: But if we are to texas republican critical thinking International School believe things — DONALD RUMSFELD: I could have said that the absence of evidence is not evidence of absence, or vice versa. JAMIE McINTYRE: But we just want to know, are you aware of any evidence? Because that would increase our level of college, belief from faith to something that would be based on evidence. DONALD RUMSFELD: Yeah, I am aware of a lot of evidence involving Iraq on a lot of subjects. And it is not for me to how to a synopsis for an article School make public judgments about my assessment or others’ assessment of that evidence. I’m going to make that the last question. The power of dogma versus evidence. We have been transported back to 1633.

To Galileo Galilei standing before the Inquisition disputing the for money Northfield Mount, geocentric versus the republican critical thinking International, heliocentric solar system. For the college for money Mount Hermon, Inquisition, Galileo’s calculations conflict with dogma. But for write a synopsis for an, Galileo, his calculations reveal the true nature of the universe — the true nature of reality . (The scene is memorialized in college for money Mount a painting by texas republican critical thinking of Milan, Joseph-Nicolas Robert-Fleury, Galileo Galilei Before Members of the Holy Office in college Mount the Vatican in 1633 — a painting of journal article The University, a painting with Raphael’s Disputation of the writing college essays for money Northfield, Holy Sacrament looming in the background.) These 17th century debates remind us that if you have an i write Pickering College, unshakable belief in writing college essays Hermon something, then no amount of evidence (or lack of evidence) can convince you otherwise. Argue College? (There are always anti-rationalist objections to everything and college essays Northfield Hermon anything. How To A Synopsis For An School? It is Mount curious, however, to hear them in the 21st century rather than in the 17th.) Jim Miklaszewski (NBC Pentagon correspondent), Pam Hess (former U.P.I. Pentagon correspondent) and Jamie McIntyre (former CNN Pentagon correspondent, now at NPR) were three of the reporters who questioned Rumsfeld in that exchange on Feb. 12, and I decided to interview each one of them. They were hearing about the how to write a synopsis for an article Taunton, “known” and writing essays Hermon the “unknown” for the first time. Paper Queen? What did they make of it? I wanted to interview people who may have shared my frustrations with the answers that Rumsfeld offered to questions about evidence.

Pam Hess was my favorite. She worked for U.P.I. and A.P. and is now the executive director of Arcadia, a center for sustainable food and college Hermon agriculture. ERROL MORRIS: Rumsfeld clearly liked you. PAM HESS: Yes, I think that’s true. Research Paper Queen Margaret's? He liked Mik [Jim Miklaszewski] and Jamie [McIntyre], as well.

He liked a lot of the reporters. That was my impression. Writing Hermon? As the paper School, Secretary of essays for money Northfield Mount, Defense, he had so much power, and was obviously so confident, which you could also characterize in other ways — ERROL MORRIS: In what other ways would you characterize it? PAM HESS: [Laughs] Some people would call him arrogant. I just found him to be his own version of i write an essay Pickering, “extremely confident.” And I think he appreciated reporters because we didn’t have to kowtow to writing college Northfield Hermon him. He enjoyed that he was finally in a place where people were saying what they thought. My impression was that he enjoyed the press conferences because he sort of argue College, got to bare-knuckle it.

ERROL MORRIS: He also got to perform. PAM HESS: And he loved it. He’s an eminently confident person and writing for money Northfield therefore does not shy away from being the center of attention. ERROL MORRIS: He might have liked to how to a synopsis for an article Taunton School be confronted, but it’s not at all clear to me that he was responsive to the questions. Before he gave the “known and unknown” speech, Jim Miklaszewski asked, pointedly, “What evidence do you have that Saddam Hussein is providing W.M.D. to Al Qaeda?” PAM HESS: The problem you have as a reporter is that you need facts. Writing Essays For Money Northfield Hermon? To really chase that rabbit down the hole — to take it apart — you needed more information than we had. We didn’t know that there were no weapons of mass destruction. ERROL MORRIS: But you certainly you had suspicions — PAM HESS: [The administration] may well have all believed that there were W.M.D. But honestly, if they went there and found nothing, how do you make a case for war?

When Rumsfeld was selected as Secretary of Defense, that group of people came in with him — Feith and Wolfowitz and all the rest. Kendall? Reporters would just look at their resumes and where they were coming from — and writing college essays Mount this was well before 9/11 — we were like, “How long before this war with Iraq starts?”[4] ERROL MORRIS: Did it seem like an inevitability? PAM HESS: It was a difficult environment to how can i write about myself Pickering College report in. The anti-war crowd really wanted the reporters in that room to take up their fight. College Essays For Money Northfield Mount? And that is something that we couldn’t do, professionally or ethically. We’re not there as antiwar protesters. How Can I Write College? We’re there as reporters, trying to essays Northfield Hermon assemble a public record. Write A Synopsis Article Taunton School? You had to writing college essays Northfield Hermon have all your ducks in a row to ask a question and to how to a synopsis for an Taunton be able to keep pursuing it, because he would find any weakness and take it apart. I thought of them as exit ramps.

I tried not to give him exit ramps in Mount Hermon my questions. ERROL MORRIS: You were good at your job. You asked thought-provoking questions. You confronted him repeatedly. PAM HESS: It was an intimidating room to be in sites School sometimes. ERROL MORRIS: You said that you were always looking for what would be his possible exit ramps?

Could you give me an example? PAM HESS: The “unknown unknown” is for money Northfield Hermon a perfect exit ramp. [Miklaszewski’s questions about how to write for an article Taunton School evidence were never answered.] I remember a reporter asked a question that began, “It is said that … x.” And Rumsfeld pounced on the “It is said” part: “Who says that?” If there were any adjectives or adverbs that he could quarrel with, he would. Those were the exit ramps. I learned and others learned not to go in unprepared. College For Money Hermon? You had to how can myself College put together a question without exit ramps — that is, direct and short and getting exactly to what you want to know. And whether or not he answered it is another question.

But at least you have a clear question on the record, and then you can judge his answer. I don’t mean this as an insult to him — but I think that there’s less there than people imagine. He’s who he is, and that’s it. That guy that you captured on film, that’s who he is exactly. And I think that freaks people out. Because he doesn’t have these layers of insecurity and self-doubt. Hermon? He just doesn’t. In 2003, Jamie McIntyre was the senior Pentagon correspondent at CNN.

Now, he is a familiar voice on NPR’s All Things Considered . When I called him, he compared Rumsfeld, the subject of my current film, The Unknown Known , and Robert S. McNamara, the subject of an for an article, earlier film, The Fog of War . He told me about a trip he had taken with Rumsfeld. Fog served as inflight entertainment. Did Rumsfeld watch? Was he struck by any similarities? Jamie McIntyre asked him, but his question was quickly dismissed: “No, no, I wasn’t watching … If I have time I’ll watch it.” The story resonated with me. On our first meeting, I’d asked Rumsfeld if he had ever seen The Fog of writing college essays Northfield Mount, War — I had actually sent him a copy. But it was never clear to me whether he had watched it. Notwithstanding, he told me, “that man [McNamara] had nothing to apologize for.” ERROL MORRIS: I hadn’t realized that Rumsfeld’s recitation of the known and unknown was a response to a question by Jim Miklaszewski about essay College evidence.

It was a very, very specific question. And the answer is this evasion — JAMIE McINTYRE: Pentagon reporters don’t really expect to get much information from writing college essays Northfield Mount Hermon, briefings. The real reporting at the Pentagon is texas critical thinking based on sources and relationships that you have with people — digging out the things that the Pentagon doesn’t want to say. So the briefings are a place where you can get people to college essays for money Northfield Mount put stuff on the record, and you can be on record asking tough questions. Reporters are trying to demonstrate that they’re independent, that they’re asking the tough questions, that they’re not cowed or intimidated by these officials. ERROL MORRIS: Still things do come out of press conferences. Do you remember that press conference? The known and for writing a persuasive essay the unknown? JAMIE McINTYRE: When he said it, I remember thinking, “Yeah, that’s true. It’s sort of self-evident, but it’s true: the things that we know, and the things that we don’t know, and the things we don’t know we don’t know.” After that, I remember some people were portraying it as some sort of gaffe — some bit of nonsense he had said that was convoluted and didn’t make any sense.

Bob Gates, who came after Rumsfeld, had his own version of this thing. He came from an intelligence background, and he used to Northfield Mount talk about the difference between “secrets” and “mysteries” — secrets being things that were knowable but we just don’t know them, and mysteries being things that are basically unknowable — as the difficulty that policy-makers have in making decisions about things because of the information they don’t have, the imponderables. ERROL MORRIS: I sometimes think of it as the for writing a persuasive essay Centennial, epistemology from hell: the known known, the known unknown — JAMIE McINTYRE: What you see in Rumsfeld is based on how you feel about him. I actually liked him a lot. There’s a tendency to for money Northfield Mount really demonize him, or, for the few people that really love Rumsfeld, to lionize him. ERROL MORRIS: I was often struck by the difference between Rumsfeld and Robert McNamara. McNamara said that he never answered the question he was asked but rather the question that he wanted to be asked.

Rumsfeld, on the other hand, would never answer the question he was asked or any other question — Ask Rumsfeld a question, and all you get is evasions. But are they just evasions or do they reveal a lack of substance? And McNamara expressed regret — JAMIE McINTYRE: I know Rumsfeld well enough at this point to what is an journal The University of Sheffield know that he’s never going to have this kind of epiphany. Essays For Money Mount Hermon? He’s never going to have this introspective moment where he realizes, even though we had the best intentions, that many of his decisions turned out to be disasters. Argue College? It was rare that he would ever admit that he was wrong about anything. Part of writing essays for money Northfield Mount, his defense was that he was very adept at how to write a synopsis for an article Taunton, putting caveats into everything that he said so that he could go back later and cite the caveat. “I never said how long the war would last.” “I never said how many troops would be needed.” “I never said how much it would cost.” He was very slippery. You couldn’t pin him down on things. And his favorite technique, of college essays for money Northfield Mount, course, was to challenge the premise of your question and texas republican International School never actually answer it.[5]

Jim Miklaszewski has been the chief Pentagon correspondent at NBC for Hermon, over 20 years. Article Taunton? He’s still there. ERROL MORRIS: Everybody knows about the known known, the known unknown, etc. But the first time Rumsfeld publicly mentioned it was in response to college Mount Hermon a question you asked — “What evidence do you have that Saddam is giving W.M.D. to terrorist organizations?” JIM MIKLASZEWSKI: There were many people within the U.S. military asking the same questions internally — “Have you seen or heard anything about the Kendall, existence of writing Mount Hermon, W.M.D.s?” Which was a strong indication that many people within the Kendall College, senior military ranks were not convinced.

ERROL MORRIS: I think it’s amazing that people in the military were asking you for essays, information about W.M.D. But you never really got a reply — JIM MIKLASZEWSKI: I mean, what do you do at a press conference? I thought I had challenged him about as far as he was going to for writing essay Centennial let me go. College Essays For Money Mount? Not that I needed his permission. But it was clear that he was not going to answer it beyond that, at that point … Whenever we go to International School of Milan these briefings and we question anybody — and particularly the secretary of defense — we’re not looking for opinions, we’re not looking for political spin. We’re just looking for facts. That’s what drives this press corps, covering the military in particular: “Just give us the facts and let us report them.” ERROL MORRIS: You have a look on your face — maybe this is just my interpreting it — a look of bemusement. JIM MIKLASZEWSKI: Oh, no.

Most good reporters are, in a sense, like lawyers — you ask a question, having a sense of what the answer, or at least part of the answer, is going to be. Writing College Essays For Money Northfield Hermon? But with Rumsfeld, that really was never the case. ERROL MORRIS: Could you see the war coming? Did it seem like the die was cast already in early 2002? JIM MIKLASZEWSKI: Well, I think the republican International of Milan, die was cast not only concerning weapons of mass destruction, but concerning the invasion and the immediate aftermath. For months after the Iraq war began, many — not just in the Pentagon but in the administration — failed to essays Northfield Mount Hermon recognize that while the invasion was a success, the steps that the U.S. Republican Critical Thinking International? had taken immediately following the invasion were crumbling before their eyes: the de-Baathification, the writing essays for money Northfield, disarming and write a synopsis article Taunton dissolution of the entire military. This was something that Rumsfeld used to talk about, too, in the days after Baghdad fell. He was very dismissive of the fact that the looting [in 2003] signified anything except a brief period of lawlessness. College Essays Northfield? But, again, I harken back to some of the republican of Milan, military leaders who saw that, and writing essays for money Northfield Mount Hermon immediately recognized that there was no structure left there, which did not bode well for a synopsis for an article Taunton, the immediate, if not the distant, future security of Baghdad or of the entire country.

ERROL MORRIS: Do you think that Rumsfeld was in denial? That even he couldn’t see his way to the facts through the layers of fantasy that he constructed in promoting the college essays Northfield, Iraq war? JIM MIKLASZEWSKI: Well, not just him but the entire building was in denial. Doug Feith — don’t get me started on Doug Feith — told me that they had a Marshall Plan all set to go in terms of rebuilding Iraq. And he pointed to this stack of huge three-ringed binders, all of them black. There must have been about 10 of them stacked up on top of a cabinet. And I asked to see them, and he said, “No, you can’t. It’s classified.” And I said, “Well, O.K., I understand that, I guess.” But I raised it to how to a synopsis for an somebody else within the next couple of weeks. I said, “Well, Doug Feith showed me the Marshall Plan for essays Northfield Hermon, Iraq.” And this person laughed, and he said, “Mik, that was the how can i write an essay about, Marshall Plan.” It was a copy of the original Marshall Plan, not a plan for Iraq.

ERROL MORRIS: Was Feith responsible for these, the two edicts that came out of Bremer — the de-Baathification edict, the disbanding of the military?[6] JIM MIKLASZEWSKI: Well, no, because Rumsfeld would not have delegated that kind of authority or power to Feith, either. College Essays For Money Northfield? There were certain people that you could tell he would listen to intently, but it always looked to me, whenever Feith came around, it was, Rumsfeld was just very dismissive. He’d say, “O.K., well” — and then sort of shoo him away. ERROL MORRIS: So who did Donald Rumsfeld listen to? JIM MIKLASZEWSKI: Donald Rumsfeld. A couple of months after our discussion I received an write a synopsis for an Taunton, email from Pam Hess.

She had written down some notes, and writing for money Mount Hermon finally decided to send them to is an academic article The University me. Essays Northfield Hermon? She described these thoughts as “the mice running around in her brain opening up old doors.” With regard to your central question: was it frustrating to i write an essay about myself Pickering cover Rumsfeld? The answer is no, mostly. I saw who he was pretty clearly and I didn’t expect to writing college for money Mount get much out of him — at least nothing he didn’t want to share — so I usually wasn’t frustrated. Paper Queen School? He met my expectations. And to say it was frustrating would suggest that I thought I “knew” the truth and just couldn’t get him to admit it. But the fact is, I didn’t know what was true regarding the college essays for money Northfield Mount, intelligence — none of us did. So I tried to nibble around the edges of what was knowable. If I couldn’t see and texas republican critical thinking of Milan judge the value of the intelligence for myself, I could at least try to writing figure out his decision process, what his thinking was, why he felt so clearly and strongly that war with Iraq was the right way to how can an essay about myself Pickering go — regardless of college essays for money Northfield Mount, what the how to write a synopsis for an article Taunton School, intel said — and try to capture that for the record. I was very curious about the writing essays for money Hermon, narrative he was building.

The “why” interested me more than the “what.” A good way to describe the situation in how can an essay about Pickering College that press room in the lead-up to the war was that the administration had this black box of intelligence, its contents known only to them. We were basically asking 20 questions about what was in essays for money Mount the box. But without getting a peek at it ourselves, we were not in a strong position to challenge them factually — which is ultimately our only real power … So I’d turn over everything he said in my head, try to square it up with everything we knew, and argue it out to myself from his perspective. And many times I’d hit a brick wall — I just couldn’t make sense of what I thought I knew to be true from what he said. And then my hand would shoot up involuntarily. I have seen tape of it actually happening. Write Article School? My brow gets knitted, I cock my head, then up goes the arm. His confrontational style encouraged me to have my facts down cold before I went in writing Mount there. Steps A Persuasive College? He’d destroy you if there was a weakness in your question, and for money Northfield you’d end up giving him the exit ramp he was looking for to get out of a difficult question while scoring points with his sizable fan base on TV.

I don’t think anyone could ever get him to admit regret or question his past actions. It’s not in his DNA, and I don’t think he feels regret for anything. This is paper sites Margaret's a supremely self-assured person who believes he makes the college essays for money Mount Hermon, best decisions possible given the information and the situation at hand, and then lets the an essay myself Pickering, chips fall where they may. Critics attacked us because they thought they could do our job better — that if they had the opportunity to interrogate Rumsfeld, by golly they’d break him and get the truth! Never gonna happen. He is, I believe, exactly who he presents to writing essays for money Hermon the world.

[1] McWethy died in a skiing accident shortly after he retired from ABC News. This was his question: JACK McWETHY: Previous administrations have adopted the Taunton, policy of trying to writing college essays for money contain Saddam Hussein. And it appears from what the president has said and what Colin Powell has said that containment no longer works in the view of research paper sites Queen Margaret's, this administration, that the college essays Hermon, threat has somehow changed, increased, that the dynamics are different, and therefore regime change has become a more substantial goal for this administration than previous ones. The University Of Sheffield? Is that true? [2] These assessments appear in college essays Northfield a Rumsfeld memo from July 27, 2001, over a month before 9/11. If Clinton’s policy was containment, the policy of the for writing Centennial, new administration was regime change. [3] Pam Hess, earlier in college Northfield Mount Hermon the news conference, had asked Rumsfeld and Richard Myers (the Chairman of the Joint Chiefs) about drones and sites Queen School their use by the C.I.A.

PAM HESS: Could I just get the two of you [Rumsfeld and Myers] maybe to free associate a little bit more on that subject? We’re seeing a — DONALD RUMSFELD: To do what? (laughter) PAM HESS: Free associate. (laughs) It’s a sort of touchy-feely ’70s term. (laughter) RICHARD MYERS: I don’t believe I can — DONALD RUMSFELD: You got the writing essays Hermon, — you got the wrong guys! (laughter) RICHARD MYERS: I don’t think I can do that with you. It’s illegal. (laughter) [4] Doug Feith got his start in government in 1981 working for the National Security Council under his college mentor Richard Pipes, who headed up the steps for writing, Team B study challenging C.I.A. estimates of Soviet missile deployment. The next year, he went to essays Hermon the Defense Department to how to write a synopsis Taunton serve as Special Counsel to writing college for money Northfield Mount assistant secretary Richard Perle, neoconservative godfather. In the following years, Feith was influential in blocking ratification of changes to the Geneva Conventions that grant non-state actors prisoner of war status even if they fail to distinguish themselves from the civilian population.

Under the Bush administration, he was the number three man at the Pentagon, overseeing the Counter Terrorism Evaluation Unit, which sought and publicized links between terror organizations and state sponsors, and the Office of myself, Special Plans, tasked with postwar planning in Iraq. Paul Wolfowitz also rose to Northfield Hermon prominence through his involvement with Team B, though he previously got his start in Washington as an aide to research paper sites Queen School influential Senator Henry M. Jackson. Writing Northfield Mount Hermon? Under Reagan, Wolfowitz became Director of i write about College, Policy Planning at the Department of State and began at this point denouncing Saddam Hussein. College Essays For Money Northfield Mount Hermon? He served as Undersecretary of Defense for Policy from 1989 to 1993 under then Secretary of Defense Dick Cheney, and was the argue Kendall College, author of the policy that became known as the Wolfowitz Doctrine, promoting unilateralism and writing college essays Northfield Hermon pre-emptive military action against texas critical thinking School, potential threats. He repeatedly expressed his regret that Saddam Hussein was not ousted in the 1991 Persian Gulf War. Prior to writing college Mount George W. Bush’s election in 2000, Wolfowitz was one of the first members of a group of write article, political heavyweights called The Vulcans, who were assembled to advise and coach the future president. JAMIE McINTYRE: Mr. Writing College Essays Northfield Mount Hermon? Secretary, here’s a single question that hopefully doesn’t lend itself to a one-word answer. An Essay About? (Scattered laughter.) What about writing college for money Northfield Mount Saddam Hussein? (Scattered laughter.) DONALD RUMSFELD: (Sighs.) Exactly what is it about him that you’re interested in? (Laughter.) His health? JAMIE McINTYRE: Where is he?

Do you know where he is? Are you trying to get him? Is he likely to get away? Does it – DONALD RUMSFELD: There’s no question but that — it is hard to find a single person. It is hard to what academic article The University of Sheffield find them when they’re alive and mobile, it’s hard to find them when they’re not well, and it’s hard to find them if they’re buried under rubble.

We don’t know. And he’s not been around. Writing College Essays For Money Northfield Mount? He’s not active. Therefore, he’s either dead or he’s incapacitated, or he’s healthy and paper sites Margaret's cowering in some tunnel someplace, trying to avoid being caught. What else can one say? JAMIE McINTYRE: Will you get him? DONALD RUMSFELD: Who knows? Who knows? Time will tell.

The important things that needed to happen will happen. The regime will change, and writing college essays for money Mount Hermon the country will no longer have weapons of mass destruction. It will no longer threaten its neighbors. It will have an opportunity for i write an essay myself Pickering College, the people of Iraq to writing essays Northfield Mount Hermon participate in determining what kind of texas republican critical International of Milan, a government they want. And liberated people will be able to be free to say what they want and do what they want. They might even have a free press eventually there. [6] L. Paul “Jerry” Bremer was installed as head of the Coalition Provisional Authority for Iraq in charge of reconstruction in May of 2003. In this role, Bremer was permitted to make rules by decree. Many people believe that his first two decrees, made in late May, were responsible for plunging Iraq into college essays Northfield, chaos and steps for writing College fueling the college Mount, insurgency. Although there’s little disagreement about the effect of these decrees, there’s considerably more about whether they originated with Bremer, or, if not, where they came from. It seems unlikely that policy decisions of this magnitude would have been made without oversight from the Pentagon, the State Department or the article Taunton, White House.

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Accounts Receivable Manager Job Description Example. Accounts Receivable Managers make sure invoicing is properly carried out. Essays For Money Northfield Mount. Accounts Receivable Manager Job Description Example. What Does an Accounts Receivable Manager Do? The accounts receivable manager is responsible for ensuring proper invoicing in an organization. His/her job description usually entails collecting all monies owed by is an academic journal of Sheffield, clients to their companies for goods and services already used or delivered, but are still to be paid for. The manager works within the college essays for money Mount, standard policies outlined by the company and reflective of requirements of the customers. He/she is required to operate in steps for writing a persuasive Centennial College, the line of writing college Northfield Hermon credit and is expected to collect such monies within stipulated time period. Texas Republican Critical Of Milan. Organizations usually record these account receivables as assets on their balance sheet, since they stand as legal obligation for any customer to writing college Northfield Mount ensure cash remittance. How To Write For An Taunton. The monies are viewed as short-term interest-devoid debts. Managers responsible for accounts receivable are usually required to relate accordingly with other members of staff in for money Mount, the same unit, as well as with those from other departments towards achieving the end goal of myself quickened credit remittance.

Their job description also involves ensuring accurate and timely rating and invoicing in the company. They are expected to relate with company Executive Board, and also with Operational Managers towards achieving the goal of business vibrancy. The role of accounts receivable managers also includes implementing disciplinary measures, providing counseling and training to employees. It also involves providing orientation to new employees, scheduling of work, and assigning of writing essays Northfield Mount Hermon specific invoicing and collecting tasks to employees. Steps For Writing A Persuasive Essay. Receivable managers are equally required to writing essays Northfield Mount Hermon communicate job appraisal and expectations to designated members of staff. They are also involved with the appraisal and for writing a persuasive, planning of job contributions by other members of staff. The manager is required to writing essays for money Northfield Mount Hermon strictly adherence to procedure and policies of the organization, and to recommend compensations actions regarding other members of staff working under them and compliant customers. Organizations usually look up to accounts receivable managers to contribute information towards strategic planning and reviews, as well as implement quality productivity to ensure customer-service standards are met. Other duties receivable managers perform include relating with customers to collect accounts after such customers had been referred by clerks.

They are required to properly investigate any non-payment circumstances. They are also saddled with the responsibility of resolving conflicts and negotiating with clients. They equally handle payment expeditions. The job environment for the manager of accounts receivable is ever dynamic and so he/she needs to update personal job knowledge regularly by ensuring full participation in steps for writing a persuasive essay Centennial, as many educational opportunities as possible, like maintenance of writing college essays for money Mount personal networks and reading of related professional publications. Other roles of this position include forecasting cash as a way of supporting the company’s financial planning, and to update account receivables by simply monitoring and coordinating bank remittance and processing for daily orders of sales. Accounts Receivable Manager Job Description Example. Accounts receivable managers in most organizations are usually required to perform the tasks, and meet with the responsibilities, outlined in how to write a synopsis for an School, the job description example below: Ensure all monies due to Mount Hermon the organization are collected promptly Report and monitor any deviation from the outlined credit standards by customers Ensure accurate and timely invoicing Ensure all cash received are properly applied via proper management of all cash applications Ensure all customers have access to standard templates designed by the company for invoicing credit remittance Manage and establish all limits of write a synopsis for an article customers, while conducting credit check on the customers Compile recommendations towards improving collection and invoicing qualities Report on essays Mount, weekly basis: invoice adjustment, cash receipt, aging totals, and invoicing totals Keep company information confident towards protecting the company’s values in the public’s view Posts monthly transactions to maintain company’s account ledgers Adhere strictly to company’s internal account control by maintaining outlined financial security Develop company’s budgets. Accounts Receivable Manager Resume Preparation.

Accounts receivable manager resume can be prepared using information from the sample job description above. Republican Critical Thinking International. Such information, which highlights the major duties, tasks, and responsibilities of an accounts receivable manager, can be employed in completing the professional experience section of the resume targeting the position. Requirements Skills, Knowledge, and college essays for money Northfield, Abilities For Account Receivable Manager Job. The account receivable manager requires the texas critical thinking of Milan, abilities, knowledge, and skills outlined below to perform creditably well on the job towards achieving the company’s business goal: Minimum of writing essays Northfield Mount five years experience in credit provision and debt collections, including managerial experience High level spreadsheet operation skills with good understanding of a number of computer packages, including Microsoft Excel Good knowledge of a number of accounting software like Great Plains Accounting Top class verbal communication and writing skills Good knowledge of reporting procedures, especially DB reporting Ability to manage at texas republican thinking School, least five members of staff in the Account Receivable department Ability to supervise other members of staff in the Account receivable (AR) department and college essays for money Hermon, appropriate their work ethics Ability to identify required expertise in accounts receivable job seekers to ensure productive staffing Versatility to argue Kendall College varieties of financial software is a plus Good understanding of the SFAS Rules towards better organizational stability Good understanding of various management processes and procedures Good knowledge and understanding of writing college Northfield Mount General Mathematics Ability to get the job done thoroughly. Notice that the above skills and other qualities can also be used in making resumes for the role. Steps For Writing College. You may need to pass a job test to be hired for a position, improve your chances of making high scores today! Job Assessment Tests: How to Top Your Competition.

As part of the hiring process, most applicants that passed the for money Hermon, initial Resume/CV screening phase are required to pass an assessment test for the job or apprenticeship position they are applying for. The goal of this phase is to determine if the how to write a synopsis for an, candidate has the appropriate set of writing college essays for money Northfield Mount Hermon skills and qualities to essay Kendall College excel on the job. Find out the tests you will be needing to take for the position you are applying for; get lots of success proven Practice materials to prepare with now: Sure way to make high scores in college for money, job tests.

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The Foreign Corrupt Practices Act: An Overview of the Law and Coverage-Related Issues. By Stacey L. McGraw and Stacey E. Writing College Essays For Money Northfield Mount? Rufe [1] March 21, 2014. The Foreign Corrupt Practices Act (FCPA) was enacted in 1977 in response to revelations of widespread bribery of foreign officials by U.S. companies in order to win business. [2] FCPA enforcement actions by the Securities and an essay myself Pickering College, Exchange Commission (SEC) and the Department of Justice (DOJ), which share enforcement authority for writing college Northfield Mount the FCPA, have increased in recent years. What Academic Article Of Sheffield? For example, while the writing college Northfield Mount, SEC’s website lists a total of for writing, 15 enforcement actions between 1978 and 2000, it lists 15 enforcement actions in 2011 alone. [3] The DOJ lists four enforcement actions in all of 2002; four DOJ enforcement actions were announced or filed in January 2014 alone. Ongoing investigations have been reported or disclosed by large companies from across the spectrum, including large drug manufacturers, computer companies, media firms, and retailers, among others. FCPA investigations and the investigative costs, defense costs, penalties, and fines associated with those investigations can be significant. For example, since 2008, Avon Products, Inc. has spent about writing college essays Northfield Mount, $340 million in legal and related costs in connection with an investigation alleging that Avon violated the FCPA by how can about myself College paying or giving improper gifts to government officials in China and college essays Northfield, other countries. [4] In January 2014, Alcoa World Alumina LLC announced that it had agreed to plead guilty and pay $223 million in criminal fines and forfeitures to resolve charges that it paid bribes to a government official in the Kingdom of Bahrain. Alcoa also settled a parallel action by the SEC in which it paid an additional $161 million in what academic journal article, disgorgement. Writing College Essays For Money Mount Hermon? [5] Given the increased enforcement of the FCPA and the duration and cost of investigations and academic article The University, related litigation, it is essays for money Northfield Mount important that counsel for insurers and insureds are familiar with the law and the insurance coverage issues that may be implicated by FCPA investigations and related litigation. The FCPA contains two main components: the anti-bribery provisions, which prohibit payments to foreign officials to obtain or retain business, and the accounting provisions that require issuers to make and keep accurate books and records and to maintain an adequate system of internal accounting controls. Pickering College? The accounting provisions also prohibit individuals and businesses from college for money, knowingly falsifying books and for writing a persuasive Centennial, records or knowingly failing to implement internal controls.

Persons and entities subject to the FCPA include “domestic concerns,” which are U.S. persons and businesses. [6] “Issuers,” which are U.S. and foreign public companies listed on U.S. stock exchanges or which are required to file periodic reports with the SEC, also are subject to the FCPA. [7] In addition, certain foreign persons and businesses acting while in writing college essays Hermon, the territory of the United States may be subject to the FCPA. [8] As noted above, enforcement authority for the FCPA is shared by the SEC and the DOJ. The DOJ has an FCPPA unit within the Criminal Division’s Fraud Section. It has criminal enforcement authority over issuers as well as criminal and civil enforcement authority over domestic concerns for the FCPA’s anti-bribery provisions. The DOJ maintains a website dedicated to the FCPA and essay College, enforcement issues and writing college Northfield Mount Hermon, questions. [9]

The SEC has authority for civil enforcement of the FCPA over issuers and their officers, directors, employees, agents, and stockholders acting on the issuer’s behalf. Is An Academic Journal Of Sheffield? The SEC has a specialized FCPA unit with attorneys in writing college essays Hermon, Washington, D.C., and in argue, regional offices. The SEC’s FCPA Unit also maintains a website, which contains links to all SEC enforcement actions involving the college essays Mount, FCPA, organized by year. [10] Other organizations involved in enforcement include the Internal Revenue Service, the Department of Homeland Security, and the Federal Bureau of Investigation, which has its own dedicated FCPA unit. Generally, the anti-bribery provisions make it unlawful to offer, pay, promise to pay, or authorize payment of money, or to i write about myself Pickering, offer, give, or promise to give anything of college Hermon, value to a foreign official in order to obtain or retain business or secure an texas republican critical International improper business advantage. [11] Jurisdiction. The anti-bribery provisions can apply to conduct both inside and college Hermon, outside the United States. When the FCPA originally was enacted, its anti-bribery provisions applied only to U.S. nationals and to U.S. firms and issuers, which can be U.S. or foreign companies. Congress amended the FCPA in 1998 to academic of Sheffield, expand its scope. The anti-bribery provisions now prohibit any acts taken in college essays Northfield, furtherance of a foreign bribery scheme that occurs in the United States or uses any means of interstate communication, even if the argue Kendall College, actual communication takes place intrastate. [12] Under the alternative jurisdiction provisions of the FCPA enacted in 1998, U.S. companies or persons are subject to the anti-bribery provisions even if they act outside the United States and even if no means of interstate commerce is used. [13] Business purpose test.

The FCPA applies only to payments intended to influence a foreign official to use his or her position “in order to assist . Writing Essays For Money Hermon? . . in obtaining or retaining business for or with, or directing business to, any person.” [14] This “business purpose” test has been broadly interpreted to include bribes made in the course of business or to gain a business advantage. Research Queen School? For example, in United States v. Kay , the Fifth Circuit held that. Congress intended for the FCPA to college for money Mount, apply broadly to payments intended to assist the payor, either directly or indirectly, in obtaining or retaining business for some person, and that bribes paid to foreign officials to secure illegally reduced customs and tax liability constitute a type of payment that can fall within this broad coverage. [15] To constitute a violation of the FCPA, a payment must be made “corruptly,” [16] which means that there must be intent to wrongfully influence the recipient. Thus, a violation may be found even if no bribe is ultimately paid, if the identity of the recipient is not known, or even if the company does not ultimately receive a benefit as a result of the payment. The intent to influence corruptly is sufficient. To establish criminal liability of an individual under the steps for writing Centennial, anti-bribery provisions, he or she must have acted willfully. [17] “Willfully” generally means that the person must act with a “bad purpose” or knowledge that the for money Northfield Mount Hermon, conduct is myself Pickering College unlawful. Writing College Essays For Money Northfield? [18] The person need not necessarily know that his or her conduct violates the FCPA specifically. [19] Proof of how can an essay myself, willfulness is relevant only to essays Mount, violations by individuals; willfulness is not required to establish corporate criminal or civil liability. An improper payment may be anything of value. [20] This includes not only cash payments; it may also include travel expenses, entertainment expenses, or expensive gifts. Gifts may also be prohibited, particularly if they are lavish or excessive. Likewise, foreign charitable contributions are not prohibited under the FCPA unless made for the purpose of improperly influencing a foreign official or made without a proper vetting of the foreign charity.

Further, an i write Pickering improper payment need not be made directly to a foreign official; payments to writing for money, friends or family members of an official may also violate the FCPA, if made in order to influence the how to a synopsis for an article, official. Writing College Northfield? [21] Who is a foreign official? Under the is an journal of Sheffield, FCPA, “foreign official” means. any officer or employee of a foreign government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on college essays for money Northfield Hermon, behalf of an essay about College, any such government or department, agency or instrumentality, or for for money Mount or on behalf of any such public international organization. Argue? [22] The term “instrumentality” has been construed broadly and may include state-owned companies or other state-controlled entities. [23] The ownership, control, status, and writing for money Mount Hermon, function will be examined to determine whether an entity is an agency or instrumentality of a foreign government. “Foreign official” includes employees and representatives of argue Kendall, “public international organizations.” [24] These are organizations that are specifically designated by executive order under the International Organizations Immunities Act, 22 U.S.C. § 288. [25] Currently, this includes organizations such as the World Bank, the International Monetary Fund, the World Trade Organization, and the Organization of American States. Payments to essays for money Northfield, third parties.

The FCPA specifically prohibits improper payments to foreign officials made through third parties or intermediaries. What Is An The University? It prohibits payments to “any person, while knowing that all or a portion of such money or thing of value will be offered, given, or promised, directly or indirectly” to a foreign official. [26] Accordingly, liability may not be avoided simply by outsourcing the payment of the writing essays Mount Hermon, bribe to a third party. Conduct is considered “knowing” if the person is aware that there is a high probability that an illegal payment is going to occur. [27] Congress intended to impose liability not only on those with actual knowledge but also on those who purposefully avoid actual knowledge“head in the sand” conduct. [28] Willful blindness to FCPA violations does not protect a company or individual from liability under the statute. Affirmative defenses. There are two possible affirmative defenses under the write a synopsis article Taunton School, anti-bribery provisions: the “local law” defense and the “reasonable and bona fide business expenditure” defense. Hermon? [29] The local law defense is texas International School applicable when the company can show that a payment was lawful under the writing for money Hermon, written laws of the essay Kendall, foreign country at issue. [30] The “reasonable and bona fide business expenditure” defense applies if the company can show that the money spent was reasonable, bona fide, and directly related to essays for money Hermon, the performance of essay Kendall, a contract, or marketing, promotion, or product demonstration. [31] In addition to these affirmative defenses, the anti-bribery provisions of the FCPA also contain a narrow exception for “facilitating or expediting payments” made in furtherance of routine governmental action that involves nondiscretionary acts. [32] Payments made under imminent threat of physical harm do not violate the FCPA because there is no corrupt purpose, but economic coercion is not sufficient to excuse an otherwise improper payment. [33] This exception, however, is in conflict with many local anticorruption laws.

Statute of writing college for money Northfield Hermon, limitations. No specific statute of limitations is provided for in the anti-bribery provisions of the FCPA; therefore, the general five-year limitations period applies to substantive criminal violations of the research Queen Margaret's School, act. [34] In cases involving conspiracies, the government may be able to reach conduct occurring before the five-year limitations period because generally the government need only prove that a single act in furtherance of the conspiracy occurred within the writing college for money Mount Hermon, limitations period. The limitations period also may be extended by a tolling agreement, or the government may apply for an extension of up to three years in argue Kendall, order to obtain evidence from foreign countries. [35] The five-year limitations period also applies to writing essays Mount Hermon, civil actions for penalties. [36] However, the SEC may bring actions for research paper Queen Margaret's equitable relief or disgorgement of ill-gotten gains outside the college for money Northfield Mount, five-year limitations period. Again, the limitations period may be extended by a tolling agreement, and in cases involving foreign individuals, the limitations period is tolled for any period during which the individuals are not found within the United States. [37] The FCPA’s accounting provisions contain two main components. First, the books and records provisions require issuers to journal, make and keep records that accurately and fairly reflect an issuer’s transactions and dispositions of assets. [38] Books and records provisions are intended to writing college essays for money Northfield Mount Hermon, prevent the mischaracterization or concealment of bribes. Second, the FCPA contains provisions regulating internal controls, which require that issuers devise and maintain a system of internal accounting controls sufficient to ensure management’s control, authority, and responsibility over i write about myself, the firm’s assets. [39] There can be civil liability under the writing college essays for money Northfield, accounting provisions for both companies and how can i write myself Pickering College, individuals. Essays Mount Hermon? In addition, both individuals and companies can be criminally liable for knowingly failing to paper School, comply with the FCPA’s accounting provisions. [40] However, the writing college, FCPA’s accounting provisions apply only to issuers; the accounting provisions do not apply to private companies. [41] Penalties, Sanctions, and Remedies.

Corporations and other business entities are subject to fines of up to $2 million for each knowing violation of the anti-bribery provisions. [42] Individuals are subject to a fine of up to $100,000 and imprisonment for sites Queen up to five years for willful violations. [43] For each willful violation of the accounting provisions, business entities are subject to writing college essays for money, a fine of up to $25 million. Individuals are subject to a fine of up to $5 million and imprisonment for up to 20 years for criminal violations. [44] Additional fines may be imposed by the courts under the Alternative Fines Act, 18 U.S.C. § 3571 (d). The DOJ may pursue civil actions for research paper sites Queen School anti-bribery violations by domestic concerns and writing college Mount Hermon, their affiliated persons and by research Margaret's foreign nationals and companies for violations while in the United States. The SEC may pursue civil actions against for money Hermon issuers and their affiliated persons for violations of the accounting provisions. For Writing A Persuasive College? A civil penalty of for money Mount Hermon, up to $10,000 per violation is available for an essay about myself violations of the anti-bribery provisions (for both entities and individuals). [45] For violations of the accounting provisions, the SEC may obtain a civil penalty of up to a certain specified dollar amount dependent on college for money Northfield Hermon, the egregiousness of the violation, or the gross amount of the pecuniary gain to the defendantwhichever is a persuasive College greater. [46] There also may be collateral consequences resulting from writing for money Northfield Hermon, FCPA violations, including suspension or debarment from contracting with the federal government, cross-debarment by multilateral development banks (such as the World Bank), and suspension or revocation of certain export privileges. Insurance Coverage Issues.

Notice. Many, if not most, FCPA investigations originate as internal investigations by the companies. After an what is an The University internal investigation is writing for money Mount completed, a company may determine that it should “self-report” to the SEC or DOJ, at which point the SEC or DOJ may commence its own investigation. A company conducting an internal investigation should consider when it is appropriate or necessary to give notice to essay College, its insurer of a claim or potential claim. Different policies contain different notice requirements, so it is for money Mount Hermon important for insureds and insurers to be familiar with the notice language and requirements of their policies and to proceed accordingly. Claim. How Can? Whether a government investigation constitutes a claim and when a claim arises depends on the language in writing essays for money Hermon, the specific insurance policy. Some policies define “claim” to include government investigations, but often only if such investigation is commenced by a formal order of steps a persuasive, investigation, subpoena, or other such formal document.

Because many FCPA investigations begin informally or possibly with self-reporting after an internal investigation, a claim may not arise until long after a company first becomes aware of possible FCPA violations. Moreover, a company may choose to agree to cooperate with the SEC or DOJ, thus delaying or avoiding a subpoena or other formal compulsory process or procedure that would constitute a claim under the company’s insurance policy. Under some policies, an FCPA or other government investigation may not constitute a claim under any circumstances. As always, it’s important to be familiar with the particular policy language. Worldwide coverage. FCPA investigations may be followed by or proceed concurrently with investigations in other countries, such as bribery investigations under the United Kingdom’s Bribery Act 2010, which took effect in July 2011. Coverage for such foreign investigations may be available under policies that provide worldwide coverage, if the matter is otherwise covered based on the language of the particular policy. Selection of defense counsel. Writing College For Money? Insurance policies that do not contain a duty to defend typically provide that the insured must obtain the argue essay Kendall College, insurer’s consent to its selection of defense counsel.

Because, as noted above, defense counsel may have been retained long before a claim arises and is tendered to the insurance carrier, there may be issues for insurers and insureds to negotiate with respect to the choice of defense counsel, the rates charged, and possible coverage of pre-notice or pre-tender defense expenses. Fines and penalties. The amounts payable for violations of the FCPA are fines and penalties, which typically are not covered by professional liability insurance. However, there may be policies or endorsements available that provide limited coverage for certain FCPA fines or penalties. In addition, some policies may provide limited coverage for writing Northfield Mount Hermon FCPA-related defense costs, even in the absence of coverage for texas International of Milan the fines and penalties themselves. Follow-on litigation. As in college for money Northfield Hermon, other governmental investigations, an FCPA enforcement action often will trigger follow-on actions, such as class actions by shareholders alleging securities fraud, derivative actions alleging breach of fiduciary duty and based on the same conduct alleged in the FCPA investigation, or congressional investigations. These types of lawsuits typically are covered by directors’ and officers’ liability policies. I Write Pickering College? Even if these actions ultimately are unsuccessful, they add to the overall costs of defending an writing college Northfield Mount FCPA investigation. Exclusion for intentional acts and imputation. A Persuasive? Exclusions barring coverage for intentional, willful, or fraudulent acts may apply to FCPA matters.

Many times, these exclusions require a final adjudication of writing essays Northfield Hermon, intentional or fraudulent conduct. However, if such a final adjudication occurs, the insured may be required to texas critical International School, reimburse the insurer for any defense costs advanced on its behalf. However, with respect to the application of exclusions, such as the exclusions for intentional acts, insurance policies may contain non-imputation clauses providing that the knowledge or conduct of one insured cannot be imputed to other insureds for purposes of determining whether the college essays for money Hermon, exclusion applies. A Persuasive Centennial? A policy also may provide that only certain persons’ knowledge can be imputed to an insured entity. For example, some policies provide that only the chief executive officer’s or chief financial officer’s knowledge may be imputed to the company. FCPA investigations and enforcement actions are on the rise and, along with parallel shareholder litigation, may lead to increased exposure for both insureds and insurers. Counsel for college essays Mount Hermon insureds and insurers should be aware of the texas republican critical International School, related insurance coverage issues as they apply in the context of FCPA enforcement actions and related litigation. Keywords: litigation, insurance, coverage, Foreign Corrupt Practices Act, FCPA, anti-bribery, fines and penalties, exclusions. [1] Stacey L. McGraw is a partner in the Washington, D.C., office and Stacey E. Essays For Money? Rufe is an associate in the Richmond, Virginia, office of Troutman Sanders, LLP, where they both represent insurers in complex coverage disputes and litigation. The views stated in this article are the views of the authors and do not necessarily represent the views of Troutman Sanders, LLP, or its clients.

[2] The 2012 Resource Guide to the U.S. What Article The University? Foreign Corrupt Practices Act published by the Criminal Division of the U.S. DOJ and the Enforcement Division of the SEC is the best source for additional information about the FCPA. College Essays Northfield Mount? See also Mike Koehler, “The Story of the FCPA,” 73(5) Ohio St. L.J. An Essay? 93238 (2012) (providing history of the drafting and passage of the for money Hermon, FCPA). [4] Serena Ng Anna Prior, “SEC Warning Sinks Avon,” Wall St. J. , Nov. 1, 2013. [5] “Alcoa to Pay $384 Million to Settle Bribery Charges,” N.Y. Paper Sites School? Times , Jan.

9, 2014. [18] See United States v. Kay , 513 F.3d 432, 44748 (5th Cir. Writing Essays Northfield Mount Hermon? 2007) (discussing common-law definitions of “willfully” and level of knowledge required to establish willful violation of the FCPA). [19] See Kay , 513 F.3d at 448 (holding that defendant need not know the terms of statute and know that he was violating statute in order to have “willfully” violated the FCPA). [21] See, e.g. , United States v. Liebo , 923 F.2d 1308, 131112 (8th Cir. 1991) (sufficient evidence existed for jury to conclude that gifts given to official’s cousin were given “corruptly” to “obtain or retain business” in critical thinking, violation of FCPA). [23] See, e.g. , United States v. Essays For Money Mount Hermon? Aguilar , 783 F. Supp.

2d 1108 (C.D. Cal. 2011) (motion to dismiss denied because electric utility wholly owned by Mexican government may be considered an “instrumentality” of a foreign government within the meaning of FCPA). Copyright 2017, American Bar Association. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or downloaded or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. The views expressed in this article are those of the author(s) and do not necessarily reflect the what academic article The University of Sheffield, positions or policies of the American Bar Association, the Section of college essays, Litigation, this committee, or the employer(s) of the author(s).

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