“Antic called me at home to tell me not to sign anything. I want you to be with me” Philosophy as a technician: “I am not a coach of the Spanish school, nor of the Serbian. I was more inclined to the Dutch. Direct and specific orders, without thinking so much about the system. That is more for the official photo before the game. I care more what happens in the game. “Experience at Atlético B: “The first five days of preseason with Atlético B were the hardest and hardest in my professional life. I met up to 36 players. 29 of the squad and 7 who were on trial. We went up to Los Angeles de San Rafael to train in a campito. And when I say campito it is because it was; it did not have the usual dimensions. There I had to prepare a training for 36 players, almost without space for everyone. To prepare for training in these conditions, I hardly slept the night before “The hardest part of being a coach: “I thought, at first, at least that’s how they told me, that the club would be communicated to the discarded. But no. The sports director did not do that function either. In the end I had to be the one to tell the kids. “Pressure as a technician: “There was also the added pressure because of what people expect from you. I had enjoyed great moments as an Atlético de Madrid player, but if the results weren’t good, it wasn’t going to last long there.”Exit through the back door: “Sign us a great season where a great generation of players got together. There was, for example, Saúl; Manquillo, who has had a great international career. At the end of the season, he had one more year of contract and the club, for things I made the decision not to renew myself. The explanation was that I was not a coach for Segunda B, but for a bigger team. I did not share that argument, but I accepted it without getting angry. “He dreams of training Atlético: “My great dream remains intact: to train Atlético de Madrid. And I am sure that moment will come. I am a very ambitious person who, sooner or later, ends up achieving what he wants.” The Serbian player now narrates, in the first person, to The Coaches’ Voice how his arrival at Atlético was conceived and his first months in the discipline of Atlético. ‘An unfinished story’ It is his story and his dreams, at 53 years old.Radomir Antic: “Our story begins at the Partizan in Belgrade. He was the coach, ‘El Maestro’ as I call him. After a while, he went to the Spanish League, with Zaragoza, and I played Greece, Panionios “Panionios: “Really the season 1994-1995 was being very good for me, perhaps the best in my career as a player: 20 assists and 17 goals. I had one more year of contract with Panionios and the club had the intention of prolonging it. Also I had two offers on the table, one from the Belgian league and one from France. “Antic’s Call: “Antic asked me for a video to see how he was playing at Panionios .. I said to him: ‘Coach, that is going to be very difficult, nobody keeps that kind of thing here.’ One day I met a Greek journalist who worked on TV and I told him to prepare a tape of my four years in Greece. I sent it to Antic. It wasn’t even two days after he called me back to tell me not to sign anything. Now I am negotiating with some teams and I want you to be with me “ Preseason 1995: “I went to Serbia to do the preseason with Panionios. The toughest of my life. We had a Romanian coach, Inre Jemey, who won the European Cup final in Seville with Steaua from Bucharest. It was great, but very hard. We had up to three training sessions in the same day. In the middle of the concentration I found out that Antic had signed for Atlético de Madrid. Names began to appear in the press: Robert Prosinecki, Enzo Scifo … So many more names. But not mine, and I without knowing anything about Antic. “Athletic transfer: “When he returned from the preseason, he contacted me again, with a very clear message: ‘I want to sign you for Atlético. And it will be like this.’ I had one more year of contract with Panionios and I called the president: ‘I know how It is Jesús Gil and everything that is said about him as president of Atlético, but I have to prove it. I think I am worth it for this. “I was curious to know if he really was ready to play at that level. My signing for Atlético de Madrid it was a fate thing, a story you could make a movie about. “ Simeone: “In that team I had Simeone as a roommate. A competitive player to the maximum, always with a winning mentality. That helped us a lot to the rest, and also, the year of the double scored many goals even though it was not his specialty A basic piece within the team At Atlético del doblete we were all Antic collaborators Each of us had to do our job for the good of the group Simeone did his perfect job, and he is doing it now as a coach His results speak for yes alone. “Difficulties to be a coach: “I had prepared very hard for this new step, becoming aware of what I wanted to do even before I stopped playing. However, it was not easy to get the title out. Unlike many other professional players, I could not do the course intensive offered by the Federation. It did not meet the requirements. So I had to go the way that most coaches go. Three years of preparation where I learned a lot about Spanish football. “ “Simeone is doing a perfect job now. Her results speak for themselves.” Milinko Pantic made history in the Atlético de Madrid of the double and it was a personal bet of Radomir Antic. One of the most loved players by the rojiblanca fans, despite the fact that he only wore the elastic mattress three seasons. Before he was a hero of Panionios Greek and world promise from its beginnings in the Partizán. He was coach of the Atlético subsidiary in the 2011-2012 campaign.
Company(Headquarters) (Israel) Improper payments to official(s) in China and associated books and records and internal controls deficiencies SAP (Germany)Improper payments to official(s) in Panama and associated books and records and internal controls deficiencies (Canada) (The Netherlands)Improper payments to official(s) in Uzbekistan and associated books and records and internal controls deficiencies LAN Airlines (Chile) Improper payments to official(s) in China and associated books and records and internal controls deficiencies 2016 was a record-breaking year for Foreign Corrupt Practices Act enforcement, both in terms of the number of core corporate actions resolved as well as overall settlement amounts.As highlighted in this post, much of the largeness of 2016 FCPA enforcement resulted from corporate enforcement actions against foreign companies. (For purposes of this post, a foreign company means the “residence” of the corporate parent company and not for instance, Analogic’s foreign subsidiary or JPMorgan’s foreign subsidiary being offered up to resolve the DOJ prong of the corporate enforcement action). Specifically, of the 27 corporate enforcement actions from 2016, 11 (41%) were against foreign companies (based in many instances on mere listing of securities on U.S. markets and in a few instances on sparse allegations of a U.S. nexus in furtherance of an alleged bribery scheme). Even more dramatic, of the net $2.27 billion settlement amounts from 2016 corporate enforcement actions, approximately $1.44 billion (63%) resulted from enforcement actions against foreign companies.Given that all of the foreign companies that resolved 2016 FCPA enforcement actions were from peer OECD Convention countries, the question should be asked whether these FCPA enforcement actions represented a proper use of the FCPA – at least from a policy standpoint.The below chart (pardon the spacing issues, working with charts in WordPress is a bear) highlights the 2016 FCPA enforcement actions against foreign companies. AstraZeneca (Brazil) Save Money With FCPA Connect Keep it simple. Not all FCPA issues warrant a team of lawyers or other professional advisers. Achieve client and business objectives in a more efficient manner through FCPA Connect. Candid, Comprehensive, and Cost-Effective. Nordion (United Kingdom) Improper payments to official(s) in India and associated books and records and internal controls deficiencies Improper payments to official(s) in Russia, Ukraine and Mexico Embraer (Belgium) Odebrecht / Braskem Improper payments to official(s) in Brazil, Angola, Argentina, Brazil, Colombia, Dominican Republic, Ecuador, Guatemala, Mexico, Mozambique, Panama, Peru, and Venezuela and associated books and records and internal controls deficiencies Improper payments to official(s) in Dominican Republic, Saudi Arabia, Mozambique, and India and associated books and records and internal controls deficiencies VimpelCom From a policy perspective, what legitimate U.S. law enforcement interests are implicated when, for example, a German company interacts with Panamanian officials; a Canadian company interacts with Russian officials; a United Kingdom or Swiss company interacts with Chinese officials; a Brazilian company interacts with officials in Dominican Republic, Saudi Arabia, Mozambique, and India; or an Israeli company interacts with officials in Russia, Ukraine and Mexico?As alluded to above, all of the 2016 FCPA enforcement actions against foreign companies were against companies headquartered in countries that, like the U.S., are parties to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Convention).In other words, Germany, Switzerland, the Netherlands, Canada, Brazil, Israel, Belgium, and Chile are all “peer” countries with mature FCPA-like laws governing the conduct of their companies coupled with reputable legal systems to prosecute such offenses.Given this reality, as well as the specific provision in Article 4 of OECD Convention that “when more than one Party has jurisdiction over an alleged offence described in this Convention, the Parties involved shall, at the request of one of them, consult with a view to determining the most appropriate jurisdiction for prosecution,” can it truly be said that the U.S. is the most appropriate jurisdiction to prosecute certain foreign companies for alleged interactions with non-U.S. officials?In the minds of some, FCPA enforcement has become a convenient cash cow for the U.S. government. The above enforcement actions in 2016 against foreign companies, which resulted in approximately $1.44 billion flowing into the U.S. treasury, only amplify these concerns.From a historical perspective, it is worth noting that part of the FCPA reform discussion in the 1980’s were bills – introduced by Democrats – seeking to waive the FCPA’s provisions “in the case of any country which the Attorney General has certified to have (1) effective bribery or corruption statutes; and (2) an established record of aggressive enforcement of such statutes.” (See S. 1797, Competitive America Trade Reform Act of 1985, introduced on October 29, 1985 by Senator Gary Hart (D-CO) and H.R. 3813, Competitive America Trade Reform Act of 1985, introduced on November 21, 1985 by Representative Vic Fazio (D-CA)).While waiving the FCPA’s provisions – as those bills sought to do – does not seem like a good idea, perhaps the time has come with the maturity of the OECD Convention – for U.S. enforcement agencies to adopt a policy of not bringing FCPA enforcement actions against foreign companies from peer OECD Convention countries. Improper payments to official(s) in Russia and associated books and records and internal controls deficiencies General Allegations Improper payments to official(s) in China and Russia and associated books and records and internal controls deficiencies ABInBev Novartis (United Kingdom) Teva Pharma Improper payments in Argentina and associated books and records and internal controls deficiencies (Switzerland) (Brazil) GlaxoSmithKline Connect