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Do You Have a Windows 95 FCPA Compliance Program?

Tom Fox | September 3, 2015

I find the world of sports to be a rich source of tutorials on things not to do for the FCPA compliance practitioner; from suspending Tom Brady for events which happened after DeflateGate, to the St. Louis Cardinals hacking the Houston Astros (of all teams) to steal secrets around player evaluations, 2015 has been a great year for lessons learned from the world of sports that carry weight in Foreign Corrupt Practices Act compliance.

Today we have one across the pond, from that paragon of soccer royalty, Manchester United. (Full disclosure: my wife is a huge ManU fan; me, the Liverpool Football Club). The lesson is not around policies or procedures, or even how to treat people, but in the arena of technology.

ManU was trying to sell player David De Gea to the Spanish club Real Madrid. In the byzantine rules of European soccer-player movement, there was a transfer window that closed at midnight on Aug.31. De Gea was fine with the deal, as Madrid is his hometown.

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