Relationship with Luis Enrique: “Luis Enrique? I do not want to be angry with anyone, I would like to have a good relationship with him. Work with him? That is already very difficult. I would not be here without him. The situation is sad. It hurts a lot, it is very unpleasant. I don’t know yet why Luis Enrique told me he didn’t count on me. They have been very exceptional circumstances, it’s something that I wish hadn’t happened, as I said at the time. “Signing for the Premier: “Luis Enrique didn’t want to take me to the Premier.”Role change with Luis Enrique: “That Luis Enrique is my second coach ever? Have we ever made the joke (laughs). It’s very difficult, there are too many things in between.”First coach: “The fact of being a first coach has come to me ahead of time. It was not in my head to see me in this situation. Life surprises you. I did not consider this for a few years. It is true that I always had the illusion of having been first coach and to become professional, but it was not at all in my mind to see me in this situation. Football surprises you, life surprises you. “Return to the Selection: “I would love to be a Spanish coach again. It would be wonderful.” National Team Players: “With some player of the National Team I keep talking, let’s see if I bring someone to Monaco (laughs). After the start, many players from the National Team and many people from the RFEF wrote me.Euro 2020: “I want Spain to win the Eurocup. In the months I was there, I saw the team grow. That is what I think about that. Then another thing happens that I said and did, which is that at the time Luis wanted to return I was going to take a step to the side. Even knowing that this meant disappearing from the play I was consistent with that. “Casillas, next president of the Federation:“Casillas president of the RFEF? Why not, I would do well.”Who would you vote for, Rubiales or Casillas ?: “I don’t have to vote.”In August, he said Rubiales was the best president in the world: “I said that at that time. I have no reproach. In life when you keep anger inside, who is hurt is the one who keeps it.”Monaco proposal: “Monaco told me that it was their only option and that made me opt for them. Monaco told me that my way of facing the National Team’s exit helped to come.”Offers: “I have had offers from almost 5 continents.”Mbappé to Madrid: “If Mbappe will go to Madrid? I hope he and Neymar.”The best coach in the world: “A mixture of Klopp and Guardiola”.
Free 90 Minute 2017 FCPA Year In Review Video A summary of every corporate enforcement action; notable statistics and issues to consider; compliance take-away points; and enforcement agency and related developments. Click below to view the engaging video tutorial. You really can’t make this one up and there is a reason why, unfortunately but justifiably, many view Foreign Corrupt Practice Act enforcement with cynicism.In 2012, Robert Khuzami was head of the SEC’s Division of Enforcement when the SEC, along with the DOJ, issued FCPA Guidance.The Guidance was signed by two individuals: Khuzami and then Assistant Attorney General Lanny Breuer.Just above Khuzami’s signature, the Guidance states:“The Guide is the product of extensive efforts by experts at DOJ and SEC, and has benefited from valuable input from the Departments of Commerce and State. It endeavors to provide helpful information to enterprises of all shapes and sizes— from small businesses doing their first transactions abroad to multi-national corporations with subsidiaries around the world. […] The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities. We are proud of the many lawyers and staff who worked on this project, and hope that it will be a useful reference for companies, individuals, and others interested in our enforcement of the Act.”At the Guidance press conference (see here for the prior post) Khuzami said that the “real value [of the guidance] is its clarity and transparency.”Against this backdrop, I nearly fell out of my chair when I read this recent National Law Journal profile of Khuzami. In it, Khuzami is asked: “What changes do you see under the new attorney general, Jeff Sessions?”Khuzami responded:“I think that you may get a [new] look at the Foreign Corrupt Practices Act, the anti-corruption law that is somewhat controversial, mostly due to the potential breadth of the law. There is a view that perhaps the government can do more to assist companies in deciding how they can conduct business in jurisdictions where corruption exists. Companies overwhelmingly aren’t interested in handing out bribes or engaging in corrupt behavior, but typically they find themselves operating in countries where that is the norm or accepted behavior. There’s a way of giving additional guidance or changing the law in a way that might strike a balance.”In my article “Grading the FCPA Guidance” I stated that “despite the Guidance, much about FCPA enforcement remains opaque” and that “despite the Guidance, FCPA reform remains a viable issue.”I am glad to see that a signatory of the FCPA Guidance agrees and that “there’s a way of giving additional guidance or changing the law in a way that might strike a balance.”But then again, I am not surprised because former FCPA enforcement officials frequently articulate seemingly contradictory FCPA commentary upon exiting government service. (See here and here for prior posts). View