The Man from FCPA occasionally puts on FCPA training. One of the things he highlights is not to put stupid stuff in e-mails. Such evidence can be clear signs something is amiss. However after this week, Fox has have to amend his training to add not to put illegal conduct into PowerPoint presentations to senior management, after it was reported in the New York Times that in 2006, a top technology executive at Volkswagenin prepared a slide deck for management, laying out in detail how the automaker could cheat on emissions tests in the United States.
As more and more of the internal investigation dribbles out, VW’s claim that its emission-testing defeat device was the creation of a small group of ‘rogue engineers’ is rightly dying a death of 1000 cuts. The piece noted, “It is not known how widely the presentation was distributed at Volkswagen. But its existence, and the proposal it made to install the software, highlight a series of flawed decisions at the embattled carmaker surrounding the emissions problem.”
