text: Essential Elements of Corporate Compliance 5 A GLOBAL TEMPLATE Prologue to the 5 Essential Elements 4 5 Essential Elements of Corporate Compliance 5 Introduction – Today's Compliance Environment 6 Enforcement Around the World 9 Essential Element 1 – Leadership 11 Essential Element 2 – Risk Assessment 13 Essential Element 3 – Standards and Controls 15 Essential Element 4 – Training and Communication 17 Essential Element 5 – Oversight: Monitoring, 19 Auditing and Response The 5 Elements and Key Global Guidance 22 Foreign Bribery Enforcement Actions by Country/ 24 International Organization Total Domestic and Foreign Bribery Enforcement 25 Actions by Industry 2014: Corruption Perceptions Index 26 Content 4 | 5 Essential Elements of Corporate Compliance A strong corporate compliance program is designed to help prevent corporate officers and employees from engaging in illegal practices while also addressing a wide array of other compliance and risk management challenges. In today's global regulatory environment, it is difficult for multinational companies, with extended enterprises, to effectively manage corporate compliance efforts. Although enforcement guidelines around the world vary in length, tone and language, virtually all touch upon a set of key issues that can be boiled down to five essential elements: leadership, risk assessment, standards and controls, training and communication, and oversight. These five elements serve as the organizing principles for the way Baker & McKenzie counsels our clients in the area of corporate compliance. If a company's compliance program effectively covers these five elements, it will likely meet the wide variety of law enforcement expectations around the world and assist the company in proactively (and successfully) meeting its strategic business initiatives through strong risk management. This document offers practical guidance for legal counsel and compliance professionals responsible for establishing and maintaining compliance standards within their company and throughout its supply chain. Baker & McKenzie works with companies as a dedicated compliance advisor providing practical, real world advice to assist our clients in ensuring maintenance of a best practices compliance and risk management program. We hope you find the advice contained in these pages to be helpful and informative. Prologue to the 5 Essential Elements | 5 5 Essential Elements of Corporate Compliance Enforcement authorities across the globe are placing an increased emphasis on the importance of establishing robust and risk-based corporate compliance programs. While the precise formulation and detail of the guidance issued varies, for example, under the US Sentencing Guidelines, the official guidance relating to the UK Bribery Act, or the Good Practice program guidelines endorsed by the Organization for Economic Co-operation and Development, there are key themes that are common to all. Baker & McKenzie has distilled those key themes into the following five color-coded essential elements of corporate compliance: Leadership Risk Assessment Standards and Controls Training and Communication Monitoring, Auditing and Response 6 | 5 Essential Elements of Corporate Compliance Introduction The Challenge In business, trust is the glue that binds employers to employees, customers to companies, and companies to suppliers, regulators, governments and partners. Yet several years after the financial crisis, efforts to rebuild trust are ongoing. Clients, customers, employees, and stakeholders around the world now demand greater transparency and ethical behavior from businesses with which they are engaged. Companies and regulators alike are seeking to restore trust in industries, products and services, and government. An effective compliance program is a fundamental tool in a company's ability to build trust. Maintaining a strong corporate compliance program designed to help prevent corporate officers, employees and third-party agents from engaging in illegal practices such as bribery, collusion, and fraud sounds simple enough. In reality, it's extremely challenging. Government authorities around the world are steadily raising expectations with respect to the comprehensiveness of corporate compliance programs, expecting robust policies, procedures, and controls not only for anti-corruption, but also for trade, antitrust, data privacy, and anti-money laundering compliance (among other areas). Furthermore, today's multinational companies operate in a highly competitive environment in which they have thousands of employees, multiple business partners and extensive operations throughout the world, including in emerging markets where the rules of public and commercial engagement often differ significantly from what they are used to at home. Global Trends In China, for example, foreign multinationals do most of their business with state-owned or state-operated companies, which can get them into trouble under the anti-corruption legislation of various countries, including the prohibition in the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and the Brazil Clean Company Act against making improper payments to foreign Today's Compliance Environment INTRODUCTION | 6 Leadership | 7 officials. In Russia and Nigeria, a foreign company may find it challenging to get its products into the country without bribing customs officials. And in Brazil and Indonesia foreign companies may have difficulty winning public bids without paying someone to shape the request for proposal in their favor. Companies with headquarters outside the US must also be aware of a significant trend toward enforcement by US, European, and Asia-Pacific enforcement agencies (such as the US Department of Justice, the UK Serious Fraud Office, and the Australian Federal Police) against companies in Eastern Europe, Latin America, Asia, and Africa. In fact, of the 10 largest FCPA settlements, only two involve US companies, with the rest being foreign multinationals, a number of which had no shares or debt registered in the US. Enforcement & Expectations Despite the impact of globalization on the business landscape, enforcement officials aren't giving companies any breaks for improper behavior. In fact, the dramatic increase in global anti-corruption investigations has been accompanied by the rising cost of enforcement actions, an emergence of more aggressive cross-border cooperation in multi-country government investigations, and an increasing risk of prosecution faced by individuals. These days, a Brazilian subsidiary of a US company that comes under investigation by Brazilian authorities will likely also receive a subpoena from the US government. Further, non-US anti-corruption enforcement has seen a noticeable increase in recent years – a trend likely to continue as countries around the world enact robust anti-bribery legislation to meet rising global expectations regarding anticorruption enforcement. With the stakes so high, where should companies making compliance a priority look to ensure their compliance programs meet regulators' expectations? The answer to that question has become increasingly complicated. The gold standard for what types of rules, protocols, communications and oversight a company must have in place in order to meet best practice compliance program requirements used to be contained in the US Sentencing Guidelines' (USSG) "Seven Elements of an Effective Compliance Program," originally published in 1991. Since then, however, those guidelines have been revised numerous times and other country-specific and international standards have been added to the equation. A major development with respect to compliance program best practices occurred in November 2012, when the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC) jointly released their aptly titled A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Resource Guide, a mustread for US and global anticorruption practitioners and compliance officers, addresses a wide variety of topics related to the US agencies' enforcement of the FCPA. Significantly, the Resource Guide provides direction on the hallmarks of an effective corporate compliance program and the best practices that the DOJ and the SEC expect companies to deploy when developing and maintaining a compliance program. When assessing a compliance program, the Resource Guide asks three key questions: (1) Is the program well designed? (2) Is it applied in good faith? and (3) Does it work? Importantly, the Resource Guide warns against paper tiger programs, which are often accompanied by assurances of efficacy, but in practice fail to demonstrate program effectiveness. Similarly, the global compliance landscape has evolved significantly in the past several years. In 2010, the Organization for Economic Co-operation and Development (OECD) released its "Good Practice Guidance on Internal Controls, Ethics, and Compliance." A year later, Introduction Today's Compliance Environment 8 | 5 Essential Elements of Corporate Compliance the UK Ministry of Justice published six principles for "adequate procedures" following the enactment of the UK Bribery Act. Transparency International, a leading anticorruption organization, has also established "Nine Business Principles for Countering Bribery," and the World Economic Forum's Partnership Against Corruption Initiative has become a leading voice on the global compliance stage. In light of the recent enactment of the Clean Company Act in Brazil, it is expected that Brazilian authorities will also issue detailed guidelines and expectations for corporate compliance programs. The Solution Prosecutors in the US, the UK, and other countries routinely insert compliance program requirements into negotiated resolutions with companies under investigation for corruption. This further adds to the long checklist of what enforcement agencies around the world expect companies to do to detect and prevent misconduct. The good news is that although these guidelines vary in length, tone and language, they have a lot in common. They all touch upon a set of key issues that can be boiled down to five essential elements: leadership, risk assessment, standards and controls, training and communication, and oversight. If a company's corporate compliance program effectively covers these five essential elements, it will likely fulfill the wide variety of law enforcement expectations around the world and help prevent costly prosecutions. In the event of a government investigation, a company with a robust compliance program that encompasses these five elements is much more likely to be granted compliance credit, a reduction in penalties and other forms of leniency that could ultimately minimize damages. Two key factors that prosecutors in the US and other countries consider when deciding whether to file an enforcement action include a company's level of cooperation and its preexisting compliance program. To help companies meet the government's demands for maintaining successful compliance programs, we've distilled the various standards to five essential elements based on our extensive experience working on these cases in jurisdictions around the world. For each element, we've included specific actions that companies can take to ensure they are fulfilling the requirements of each element. While our primary focus in this document is in the area of anti-corruption, the five elements framework can be practically and effectively applied in other areas of your compliance program, such as trade, antitrust, data privacy, and anti-money laundering. Our subject matter experts around the globe can provide you with the detailed guidance to apply the five elements to such areas, based on your company's unique risk profile. INTRODUCTION | 8 Leadership | 9 Enforcement Around the World US In November 2012, the DOJ and SEC jointly released A Resource Guide to the U.S. Foreign Corrupt Practices Act. This highly anticipated, watershed publication represents a comprehensive overview of the US government's enforcement positions and expectations for corporate compliance programs. The Resource Guide also includes practical guidelines for companies around the world grappling day-to-day with the challenges of designing, implementing, and enforcing a comprehensive anticorruption compliance program. UK In the wake of the passage of the UK Bribery Act, prosecutors in the UK are pursuing significant, high-profile corruption matters and charging individuals and companies with corruptionrelated offenses. In August 2013, the Serious Fraud Office brought its first Bribery Act charges and has since formally announced active investigations involving large, multinational corporations. Importantly, beginning in February 2014 with the passage of The Crime and Courts Act, UK prosecutors can now employ deferred prosecution agreements as an additional means to efficiently resolving corruptionrelated matters. CHINA As discussed throughout this document, anti-corruption enforcement is extremely active in China. Corruption and bribery are historically linked to business and government operations in the country and remain key concerns of the Chinese government and company executives. In addition to initiating many recent highprofile investigations involving multinational companies, the Chinese government also recently amended its criminal laws to cover foreign bribery, adding a new provision that criminalizes paying bribes to non-PRC government officials and to officials of international public organizations. Potential bribery targets include officials, companies (state-owned enterprises and privatelyowned companies) and their employees. A September 2014 ruling against GlaxoSmtihKline signaled the country's intent to levy large financial penalties against companies and sentence individuals to prison time for violating its laws. BRAZIL Brazil's new anti-bribery law, often referred to as the Clean Company Act, officially took effect in January 2014. The Act 10 | 5 Essential Elements of Corporate Compliance applies to business organizations in Brazil (whether incorporated or not), Brazilian foundations or associations, and foreign companies with any presence in Brazil. Under the new law, such entities can be strictly liable for prohibited acts committed in their interest or for their benefit. With this new law, Brazil has created a template with which to maximize the enforcement capabilities of the country's authorities and simultaneously set the bar for other Latin American countries to follow suit with similarly robust legislation. RUSSIA Anti-bribery initiatives in Russia are growing in strength and momentum and there is an increasing focus on enforcement. Over 160 corruption related cases have been brought against companies in the past three years and the Kremlin launched a robust anti-corruption campaign during the fall of 2012. Furthermore, there is a growing recognition in Russia that compliance is good for business, supported by measures such as a November 2013 regulation issued by the Ministry of Labor outlining recommended anti-corruption compliance guidelines for commercial and non-commercial entities. INDIA India is actively increasing its attention to a longstanding culture of bribery and corruption. Traditional anti-corruption laws in India are primarily based upon colonial laws enacted while India was under British control. However, recently proposed legislation, including the Prevention of Corruption (Amendment) Bill 2013 (currently pending before the Indian government) and the Prevention of Bribery of Foreign Public Officials and Officials of Public International Organizations Bill 2011 (currently pending before the Indian government) are expected to significantly enhance the Indian government's ability to crack down on offenders. AUSTRALIA The Australian anti-corruption landscape is experiencing rapid change. The country has active state and federal anti-corruption laws that prohibit bribery of public officials and commercial entities. Penalties are significant – up to A$ 11 million for corporations and up to A$ 1.1 million and 10 years of imprisonment for individuals. In addition, recent enforcement matters including the 2012 Securency and Note Printing Australia case have significantly raised the profile of Australia's anti-corruption regime. CANADA In 2013, Canada significantly strengthened its Corruption of Foreign Public Officials Act (CFPOA), including enhanced books and records obligations, broader jurisdiction, elimination of the exception for facilitation payments, and increased penalties. In May 2014, a judge in Ottawa handed down the first prison sentence under the CFPOA since it originally came into force in 1999. Leadership | 11 Increasingly, boards are finding that trust is on their agenda as a key business enabler – this means trust in the business, its leadership, its stakeholders, and its network of suppliers. Corporate structures and processes are essential, but they must also be fortified with values that include integrity, transparency, and respect for the rule of law. Likewise, a successful compliance program must be built on a solid foundation of ethics and integrity that is fully endorsed by senior management. Otherwise it's just a hollow set of internal rules and regulations. But compliance standards require even more than support from the top. Companies must have high-ranking compliance officers with the authority and resources to manage the program on a day-to-day basis. The compliance officers must have the ear of those individuals ultimately responsible for corporate conduct, including members of the Board of Directors. The US Sentencing Commission reinforced the importance of ensuring that compliance officers have direct access to the Board of Directors when it published amendments to the US Sentencing Guidelines in 2010. To receive a "culpability score reduction" during sentencing under the Guidelines, a company must now show that its compliance officers can promptly report any matter involving criminal conduct directly to the board or appropriate board committee. Compliance officers should also report to the board on the implementation and effectiveness of the company's compliance program at least once a year. As a best practice, however, we advise clients to take this component of their programs a step further. We recommend that a company's chief compliance officer or legal department compliance manager provide quarterly presentations to the board about ongoing internal investigations, general developments in anti-corruption laws and enforcement, compliance challenges the company is facing and what is being done to address those challenges. That way, it is clear that the line of communication between the compliance team and the board is open. Leadership What key global guidance resources say about leadership: OECD: Support from senior management is strong, explicit and visible. Program is overseen by senior corporate officers with sufficient resources, authority and access to the board. USSG: Leaders understand and oversee the compliance program to verify its effectiveness; specific individuals have the authority and responsibility to carry out the program. The company denies leadership positions to people who have engaged in misconduct. UK's 6 Principles: Top-level commitment. 1 12 | 5 Essential Elements of Corporate Compliance Ensure board level accountability for the effectiveness of your compliance program. A key element of successful compliance programs is that responsibility for developing and maintaining a culture of compliance ultimately rests with the Board of Directors. This is also where the trust-building of a company originates, as the Board must endorse ethical values at every level of the company in a manner that will influence behavior across reporting lines and help ensure these values reach all employees. Robust compliance programs require those responsible for the effective operations of the company to ensure that appropriate operational systems and corporate structures are in place to enable the company to operate in a compliant manner. A Board of Directors should therefore oversee implementation of a company's compliance program, ensure that it is effective in addressing the risks faced by the company, and provide direct supervision of those responsible for the day-to-day management of the program. And the Board should get familiar with the business, know what is happening on the ground, consider how corporate values are being followed, and ensure employees feel they can speak up with any concerns they might have. Make sure central compliance communicates with those in the field. One of the biggest impediments to effective compliance leadership is poor communication between a company's central compliance department and country managers working in the field. This can be a major oversight considering that country managers are often the employees in the trenches overseeing sales people and third-party agents who are selling and distributing the company's products and services. Neglecting to provide appropriate compliance training for country managers or keep them in the corporate loop increases the chances that efforts to establish a strong local compliance culture will fail. Management tactics such as incorporating specific compliance requirements into annual evaluation criteria and connecting compensation to performance under these requirements can be effective for guiding employee behavior towards a greater respect for compliance. Local managers are often best situated to set the tone for compliance and to detect and address illegal or unethical practices before they become compliance issues that put the company at risk. Place compliance officers in high-risk markets. Another common oversight is failing to have well-trained compliance personnel in a company's foreign offices. Maintaining a leadership structure that is too centralized will stifle efforts to foster a healthy compliance culture across all geographies and to minimize global risk. Ethical edicts issued from faraway headquarters are often ineffective without buy-in from local managers who have the training and experience to reinforce such rules. The determination of which overseas offices should have the strongest compliance presence should be made on a risk basis. Companies can begin by building an active presence of trained compliance managers in markets with the greatest compliance risk, then expand this presence to other jurisdictions. Conduct periodic board training and provide reports on hot topics in compliance and risk management. Corporate board members face the prospect of personal liability for failing to meet their fiduciary responsibilities in overseeing these policies and practices. With greater awareness of compliance issues from sources such as whistleblowers and bloggers there comes a greater duty and expectation for board members to act. By providing regular, timely compliance training for board members and keeping them updated on compliance and risk management trends, legal and compliance departments can help directors fulfill their compliance obligations and steer the company away from potential misconduct. Leverage Internal Audit, Finance, and other risk management functions. In order for a compliance program to be successful, multiple disciplines within the company must assist the compliance department in leading the way. Internal Audit and Finance are in the best position to understand the company's financial risks and are often on the front lines of identifying red flags. Leveraging their expertise and internal structure will extend the reach of the compliance program into those functions that are key to a successful compliance program. Recommendations RISK ASSESSMENT | 13 Although the original 1991 version of the US Sentencing Guidelines did not specifically identify the completion of a formal risk assessment as one of the seven elements of effective corporate compliance, Sarbanes-Oxley directed the Commission to add it to the list. As a result, government officials now routinely emphasize risk assessments as the foundation of an effective program. What changed? The answer may be globalization. As multinationals have expanded their enterprises and become more dependent on global supply chains, knowing and understanding the nature and extent of business risks has become a critical first step for implementing successful compliance programs. Enforcement authorities around the world increasingly expect multinationals to have formal processes for periodically assessing the compliance risks everywhere they do business, particularly in higher-risk regions, including emerging markets like China, Russia, India and Brazil. During the risk assessment process, companies must evaluate numerous compliance issues, including the degree to which the company's employees conduct business with government officials, the company's use of third-party agents and intermediaries, the regulatory environment of the regions where the company operates, and the effects of any recent business developments such as new joint ventures, corporate affiliations, or expansion into markets that could create additional risk. What key global guidance resources say about risk assessment: OECD: Risk assessment should be the basis for effective internal controls and compliance programs. USSG: Companies must conduct periodic assessments of risk of criminal conduct and take appropriate steps to design, implement or modify each element to reduce risk. UK's 6 Principles: Broad categories of risk must be carefully examined, including country, sectoral, transaction, business opportunity and partnerships. Program priorities, resources and controls should be determined based on the results of the risk assessment. Risk Assessment 2 14 | 5 Essential Elements of Corporate Compliance Conduct annual risk assessments. The purpose of a risk assessment is to gauge where your company's greatest compliance risks are so you can target resources in those areas and establish policies and protocols to minimize those risks. Yet it's surprising how many companies do not perform this task. Companies will often wait until something goes wrong before self-assessing. To avoid the inherent risks in the "wait and see" approach, we recommend that you conduct a formal risk assessment every year. Because enforcement trends, such as those involving anti-corruption, trade, antitrust, data privacy, and anti-money laundering laws evolve rapidly and multinationals tend to go through numerous significant changes within a given fiscal year, we have found this to be an optimal timeframe. Build this annual risk assessment into your compliance program. Not only should you conduct annual risk assessments, but you should try to perform them at the same time each year. To pass muster with government regulators, it will be helpful to demonstrate that your risk assessment is a regular, systemic part of your compliance efforts rather than an occasional, ad-hoc exercise cobbled together when convenient. We also recommend designating a specific group, such as your compliance team, internal audit department or enterprise risk management team to spearhead the annual review. This will help demonstrate to the government that your risk assessment is a formal corporate process. Scrutinize new business partners and third-party agents. One of the key areas that can get companies into compliance trouble is their lack of internal controls over business partners and third-party intermediaries such as consultants, distributors, contractors and sales agents. The majority of FCPA enforcement actions involve some use of third parties. Compliance standards require companies to conduct due diligence on new business partners and third-party intermediaries. But in the rush to close deals and enter new markets, that doesn't always happen as thoroughly as it should. Conducting a formal risk assessment each year provides an opportunity to take a closer look at newer business relationships to make sure partners and third parties do not have improper connections to government officials or involvement in unethical, improper, or illegal conduct. Any risk that you uncover should be addressed and remediated. Update your policies and procedures based on enforcement trends. Throughout the course of a year, government officials around the world file numerous enforcement actions against companies for all kinds of corporate misconduct. Paying attention to the specific compliance areas that the government is targeting in these enforcement actions will tell you a lot about what your program needs to focus on to stay out of the government's cross hairs. If, for example, you notice that the government has been clamping down on gift giving and hospitality in Asia and you conduct considerable business in that region, that should become a focus area for your risk assessment. Then, depending on whether your hospitality policies and procedures in Asia are in line with what the government now expects, you should make necessary changes. Memorialize your findings in an annual report. When conducted every year, routine risk assessments should generally take three to four weeks, depending on the size of your company and your compliance resources. Once the assessment is complete, the compliance or audit team should compile its findings and recommendations in a comprehensive report to be presented to the chief compliance officer and Board of Directors for review and consideration of appropriate program enhancements. However, the process should not stop there. An action plan that prioritizes the recommendations from the risk assessment and assigns parties responsible for implementation should then be developed to ensure that the necessary program enhancements are implemented. Recommendations STANDARDS AND CONTROLS | 15 It would be challenging to find a global company today that doesn't have a code of business conduct — an easy-to-read summary of corporate do's and don'ts. But compliance standards require that companies go much further. Besides a flagship code of conduct, corporations should have detailed written policies covering issues such as bribery, corruption, trade, antitrust, data privacy, money laundering and accounting practices, as well as clear procedures and protocols for making sure those policies are followed and enforced. A code of conduct will usually expressly prohibit bribery. However, best practices now require additional standards and controls, including detailed due diligence protocols for screening third-party business partners for criminal backgrounds, financial stability and improper associations with government agencies. Ultimately, the purpose of establishing effective standards and controls is to demonstrate that your compliance program is more than just words on paper. What key global guidance resources say about standards and controls: OECD: Company policy should clearly and visibly state that bribery is prohibited. Compliance programs should address key risk areas. Companies should conduct due diligence on business partners and implement effective internal controls for accurate books and records. Employees should be able to report violations confidentially without fear of retaliation. USSG: Companies should have standards and procedures to prevent and detect criminal conduct. They should provide incentives and discipline misconduct. UK's 6 Principles: Policies and procedures should be clear, practical and accessible. Companies should have due diligence protocols for screening third-party intermediaries. Standards and Controls 3 16 | 5 Essential Elements of Corporate Compliance Establish stringent protocols for screening business partners and third parties. In most risk assessments we perform for clients, we find gaps in the company's third-party due diligence program. Many companies have not yet created an effective platform for screening third-party intermediaries and other business partners for previous misconduct and improper ties to the government. Some companies still give their business partners only a cursory look — a considerable oversight considering how often government investigations involve allegations of impropriety by a company's third-party agents. To conduct proper due diligence, companies must require third parties and other business partners to complete background questionnaires detailing, among other things, their financial stability, foreign government ties and any history of investigations. Third parties should also declare their commitment to robust corporate compliance in a signed certification form. To increase accountability, we also recommend using business sponsor forms in which employees who refer or hire thirdparty agents provide background information about the agents, such as the experience and attributes that qualify the agents for the role they will play as new company partners. Conduct background checks on important business partners in high-risk markets. Performing background checks on third parties can be an expensive undertaking. But it may be advisable when screening major business partners and third parties in higher-risk markets to make sure they've represented themselves accurately in their paperwork. Accordingly, consider hiring trained, local investigators to get an even clearer picture of whether your potential partner could become a compliance liability. Include strict compliance covenants in your third-party contracts. Today's best practice compliance standards also require companies to monitor the conduct of third parties and other business partners. We strongly encourage companies to integrate contractual provisions with business partners that facilitate the company's ability to do so. At a minimum, these compliance covenants should cover three core concerns: adherence to the anticorruption laws that are of most relevance to the relationship, audit rights, and termination rights. More specifically, these provisions should require the business partner to agree not to violate relevant anti-corruption laws, to give the company the right to review the partner's books and records, and to enable the company to terminate the contract if it later determines the partner is engaged in misconduct, unethical behavior or illegal activity. Establish internal controls to ensure accounting records are accurate. The FCPA and the anti-corruption laws of many other countries require companies to book transactions correctly by securing receipts and accurately recording the date and amount of the payment. To be compliant, companies should reconcile bank accounts with outgoing and incoming payments every month and inquire into any suspicious payments and missing funds that could indicate misappropriation or off-thebooks transactions. Companies should pay particular attention to transactions with consultants and business development agents, customs payments, charitable giving arrangements, political contributions and gifts and hospitality involving government officials. Provide clear guidelines for gift giving and hospitality. Giving clients and business associates gifts, treating them to dinner or taking them to sporting events are common business development practices. But anything too extravagant or lavish could quickly cross the line into bribery. Differences in culture and economic prosperity can make it difficult for companies to establish one-size-fits-all giftgiving and hospitality guidelines for the countries where they conduct business. While paying $150 a head for a business dinner in Australia may not constitute bribery, in poorer countries such as Nigeria or Indonesia it could. That's why it's so important to tailor hospitality policies to individual countries. Companies can do this in any number of ways, including through the use of a thresholds table listing permissible hospitality amounts based on local laws and regulations in each country where they operate, plus advice from experienced local counsel. Recommendations TRAINING | 17 One of the most important elements of a strong compliance program is properly training company officers, employees and third parties on relevant laws, regulations, corporate policies, and prohibited conduct. In recent years, the rise of technology platforms such as webinars, video conferencing and online self-testing has made training easier and more affordable. But simply conducting some compliance training for employees isn't enough. Enforcement officials want to be sure management's compliance message gets through in a meaningful way. Thus, when determining whether a company's training program meets its expectations for effectiveness, government authorities often scrutinize who a company trains, how the training was conducted and how often training occurs. What key global guidance resources say about training: OECD: Training should be periodic, consistent, and documented. USSG: Companies must communicate the standards and procedures of its compliance program and conduct effective training. UK's 6 Principles: Effective implementation of compliance program policies and procedures through adequate training. Training and Communication 4 18 | 5 Essential Elements of Corporate Compliance Develop an annual, risk-based, training plan. Regulators in countries across the globe have come to expect companies to provide training programs. In order to demonstrate a true understanding of the anticorruption risks unique to your company, regulators will want to see that your training program is adequately comprehensive, for example, by including both computer-based and live components. Also, government authorities will seek to ensure that employees performing your highest risk activities, and those who are in a position to monitor your highest risk transactions, are regularly trained on policies and procedures designed to help minimize risk, identify red flags, and escalate or remediate compliance-related problems. A training plan should include a schedule for tracking when employees complete required compliance training. Tools for encouraging timely completion can include a reduction in performance scores for staff who do not complete required training and supervisors whose staff are delinquent. Provide live compliance training for country managers. If resources permit, officers and managers in your foreign offices should receive live, in-person compliance training every year, particularly those working in your highest risk markets. In the compliance world, anti-corruption laws, enforcement trends and government priorities change quickly. Waiting more than a year to conduct periodic compliance training can impede awareness. If lack of resources is an issue, conducting live videoconferences or webinars with question-and-answer sessions is a good alternative. Train the right people. When providing compliance training, it's important to prioritize which audience to educate first, particularly when you have limited resources. Besides country managers, it's important to focus your initial training efforts on high-risk markets and directors, officers, sales employees, and third-party intermediaries who have direct contact with government officials or deal with state-owned entities. Then expand the training around the globe and across your employee spectrum. Conduct live, annual training in high-risk markets. Enforcement officials have made it clear that live, in-person training is the preferred method in high-risk markets and that this training should be relatively frequent. Therefore, merely conducting a simple five-question online anti-corruption compliance test in a higher-risk country such as Russia, or performing training in China once every five years, will probably not be sufficient from a regulator's perspective. Also, one of the many benefits of conducting live, in-person training is that you often receive immediate feedback. During live training, employees are more likely to casually mention a potentially risky practice, giving you the opportunity to address an impropriety before it becomes a larger problem. Develop your training to address a broad range of global issues. Some companies make the mistake of having a generic script for all compliance training that misses the practical challenges employees routinely face. Training programs typically cover the FCPA, UK Bribery Act, OECD guidelines, Brazil Clean Company Act, and enforcement trends in other countries in Europe, Asia-Pacific, and South America. Additionally, you need to focus on the specific compliance risks in the country where the employees are working. In China, for example, training should address the many corruption risks of dealing with state-owned entities. In Brazil and Nigeria, training should include guidance on how to handle government officials who expect facilitation fees to move business processes along more quickly. Finally, certain functions that are key to effective compliance monitoring should receive functionspecific training. For example, accounts payable should receive training on how to identify red flags related to improper payments or otherwise signaling potentially corrupt or fraudulent activity. Update your training regularly. Enforcement trends and anticorruption laws change quickly, and government officials are increasingly collaborating across borders to conduct large-scale investigations. That's why it is important to monitor what's happening around the world and incorporate those developments into your training. Compliance is a global issue that requires corporate vigilance and constant attention. By providing timely, effective employee training, companies can demonstrate their commitment to cultivating and supporting a strong compliance culture. Recommendations OVERSIGHT | 19 After all the ethical messages have been put in place and communicated to the appropriate audiences, the question remains whether the workforce is actually complying. Two of the seven compliance elements in the US Sentencing Guidelines call for corporations to monitor, audit and respond quickly to allegations of misconduct. These three activities — monitoring, auditing and responding — are key components enforcement officials look for when determining whether companies maintain adequate oversight of their compliance programs. Many companies fall short on this element, often because of confusion about the differences between monitoring and auditing. Monitoring is a commitment to reviewing and detecting compliance problems in real time, then acting quickly to remediate them. The primary goal is to identify and address gaps in your program on a regular basis. An audit is a more limited review that targets a specific business component, region or market sector during a particular timeframe to uncover or evaluate certain risks. Some companies assume that because they conduct audits or have a dedicated auditing team, they are effectively monitoring. This is usually not the case. A robust compliance program should include separate monitoring and auditing functions. While unique in protocol, these two program components are often viewed as compliance "cousins" because they work in tandem. If, for example, you notice a trend of suspicious payments in recent monitoring reports from Indonesia, you may decide it's the appropriate time to conduct an audit of those operations to target and further investigate the issue. What key global guidance resources say about oversight: OECD: Individuals at all levels of the company should be responsible for monitoring. Companies should discipline employees for violations of the policy. Companies should regularly review their compliance programs and make necessary revisions. USSG: Companies should monitor and audit their compliance programs and maintain reporting mechanisms. They should respond quickly to allegations and modify their programs as needed. UK's 6 Principles: Companies must monitor and review their compliance programs. Oversight 5 20 | 5 Essential Elements of Corporate Compliance Establish a regular monitoring system to spot problems and address them. Effective monitoring means applying a consistent set of protocols, checks and controls tailored to your company's risks to detect and remediate compliance problems on a continuing basis. Ongoing, real-time monitoring, when effectively managed, will provide valuable insight into who a company's business partners are and the specific transactions entered into with such business partners. Monitoring compliments the risk assessment and audit processes by providing additional context for the nature and scope of high-risk relationships and transactions. It facilitates ongoing visibility into these risks for the period of time between regularly-scheduled risk assessments and audits. The result is that compliance personnel have the opportunity to thwart corruption and bribery attempts while in process. This is why your compliance team should be checking in regularly with local finance departments in your foreign offices to ask whether they've noticed recent accounting irregularities. Also, as part of their corporate compliance accountability, regional business directors should be required to keep tabs on potentially improper activity in the countries they manage. Your global compliance committee or enterprise risk group should talk as often as feasible (perhaps every month) to discuss and address issues as they arise. Ongoing efforts like these will show government authorities that you are serious about compliance. Require country managers to complete regular compliance reports. One of the nine factors that US prosecutors consider when deciding whether to file an enforcement action is whether a company is applying its compliance program in good faith. The program may look good on paper but the government wants to know, is it really working? One of the most effective ways of answering that question is being able to show prosecutors regular, periodic monitoring and auditing reports prepared by senior executives and managers across your operations. Pay attention to what employees say during training. Training is a form of monitoring because it can alert you to potential problems based on the types of questions employees ask and their reception to certain concepts. For example, during training employees sometimes ask specific questions about their interactions with government officials or gift-giving practices that can raise red flags, which should be addressed quickly. The information learned from the engagement of employees in this manner will assist the company in taking appropriate actions to initiate program improvements and further enhance corporate values. Regularly test your compliance program to verify its effectiveness. Regulators expect a well-functioning compliance program to identify program weaknesses and promptly address those weaknesses. While companies typically test their financial controls they should be mindful of testing the entire anti-corruption program, not just the financial controls system. One particularly useful method of testing is to track categories of payment methods often used by third-party agents -- such as commissions -- and require compliance to confirm that due diligence screening was successfully completed. Upon implementation of an enhanced in-person training program, periodically review hotline reports and inquiries to determine whether such reports have increased, or whether more compliance-related inquiries have been received from categories of employees who have not previously communicated with the compliance department. Conduct employee surveys to measure the compliance culture and employee knowledge and awareness of compliance practices and procedures. Establish protocols for internal investigations and disciplinary action. Responding swiftly and effectively to compliance issues will sometimes require your company to conduct an internal investigation. Each company should have procedures already in place to make sure every investigation is thorough and authentic. Those procedures Recommendations OVERSIGHT | 21 should include document preservation protocols, data privacy policies, and communication systems designed to manage information and get it to the appropriate people quickly. Best practice compliance guidelines also encourage companies to establish disciplinary policies that clearly state how they regulate and discipline employees engaged in misconduct. Remediate problems quickly. A key concept behind the oversight element of effective corporate compliance is the idea that if companies are policing themselves for compliancerelated issues, the government won't have to do it for them. That is why remediation is such an important component of oversight. If it's clear that your sales people in Thailand are doing something potentially improper partly because they never received adequate compliance training, remediate the deficiency by scheduling that training immediately. In the end, it's not enough to just gather information and identify compliance problems. To fulfill this essential element of compliance, you also have to fix them. 22 | 5 Essential Elements of Corporate Compliance The 5 Elements and Key Global Guidance USSG's 7 Elements of an Effective Compliance Program 1. Standards and procedures to prevent and detect criminal conduct 2. Leaders understand / oversee the compliance program to verify effectiveness and adequacy of support; specific individuals vested with implementation authority / responsibility 3. Deny leadership positions to people who have engaged in misconduct 4. Communicate standards and procedures of compliance program, and conduct effective training 5. Monitor and audit; maintain reporting mechanism 6. Provide incentives; discipline misconduct 7. Respond quickly to allegations and modify program NOTE: A general provision requires periodic assessment of risk of criminal conduct and appropriate steps to design, implement, or modify each element to reduce risk 1. Commitment from Senior Management and Clearly Articulated Policy 2. Code of Conduct and Compliance Policies and Procedures 3. Oversight, Autonomy and Resources 4. Risk Assessment 5. Training and Continuing Advice 6. Incentives and Disciplinary Measures 7. Third-Party Due Diligence and Payments 8. Continuous Improvement: Periodic Testing and Review 9. Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration DOJ/SEC FCPA Resource Guide Hallmarks of Effective Compliance Programs | 23 OECD's Good Practice Guidance on Internal Controls, Ethics, and Compliance 1. Risk assessment as basis for effective internal controls and compliance program 2. Policy that clearly and visibly states bribery is prohibited 3. Training – periodic, documented 4. Responsibility – individuals at all levels should be responsible for monitoring 5. Support from senior management – strong, explicit and visible 6. Oversight by senior corporate officers with sufficient resources, authority, and access to Board 7. Specific risk areas – promulgation and implementation programs to address key issues 8. Business partners due diligence 9. Accounting – effective internal controls for accurate books and records 10. Guidance – provision of advice to ensure compliance 11. Reporting violations confidentially with no retaliation 12. Discipline for violations of policy 13. Re-assessment – regular review and necessary revisions 1. Proportionate procedures 2. Top level commitment 3. Risk assessment 4. Due diligence 5. Communication 6. Monitoring and review UK's 6 Principles for "Adequate Procedures" 24 | 5 Essential Elements of Corporate Compliance Foreign Bribery Enforcement Actions by Country/International Organization 1977-2013 (N = 515) Twenty-six countries and three public international organizations (the United Nations, European Bank for Reconstruction and Development ("EBRD") and the World Bank) pursued 515 foreign bribery enforcement actions (which includes ongoing investigations) from 1977 through 2013. The US maintained the strongest enforcement record during this period, undertaking over 61% of all foreign bribery enforcement actions. The enactment of the FCPA in 1977 gave the US a considerable head start on foreign bribery enforcement compared to other countries. The US has accumulated nearly seven times as many foreign bribery enforcement actions as the country with the next highest total (the UK). Many countries have not pursued a single foreign bribery enforcement action in the 36-year period covered by the Global Enforcement Report. Source: © | 25 Total Domestic and Foreign Bribery Enforcement Actions by Industry 1977 – 2013 (N=701) This shows the industries that have experienced the most domestic and foreign bribery enforcement activity from 1977 through 2013. As in 2012, the extractive industries again represent the highest number of domestic and foreign bribery enforcement actions, although the manufacturer/service provider sector has nearly as many domestic and foreign bribery enforcement actions. These two sectors account for approximately 35% of known domestic and foreign bribery enforcement activity, and are followed by the aerospace, defense and security sector and the health care industry. These four industries had the largest number of domestic and foreign bribery enforcement actions from 2010 through 2013, and numerous companies in these industries are currently being investigated. Source: © 26 | 5 Essential Elements of Corporate Compliance Corruption Perceptions Index 175 COUNTRIES. 175 SCORES. HOW DOES YOUR COUNTRY MEASURE UP? The perceived levels of public sector corruption in 175 countries/territories around the world. 2014 | 27 Source: If you have any questions about this document or would like more information about our Global Corporate Compliance Practice, please contact: Mini vandePol Chair, Global Corporate Compliance +1 852 2846 2562 email@example.com Contacts © 2015 Baker & McKenzie. All rights reserved. Baker & McKenzie International is a Swiss Verein with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a "partner" means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an "office" means an office of any such law firm. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome. www.bakermckenzie.com Baker & McKenzie has been global since inception. Being global is part of our DNA. Our difference is the way we think, work and behave – we combine an instinctively global perspective with a genuinely multicultural approach, enabled by collaborative relationships and yielding practical, innovative advice. Serving our clients with more than 4,200 lawyers in more than 45 countries, we have a deep understanding of the culture of business the world over and are able to bring the talent and experience needed to navigate complexity across practices and borders with ease.


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YouTube Gaming is the official app from YouTube that lets you broadcast your videos live, and stream other people's videos. You can also watch any YouTube video related to the video game world. In fact, you can access the most popular video game channels in the world from the right side of the screen.
The video powerhouse YouTube has released a competitor to Twitch, the live-stream gaming platform. If you are familiar with the basic YouTube app, this is remarkably similar, just with the little extra bonus of games, all day, every day. So whether you just can't get enough Minecraft, or you really want to watch the Magic the Gathering World Championship this year, you can!
The best thing about YouTube Gaming is, without any doubt, its elegant user interface. From the very first time you open the application, you can stream live content, and see how you have everything at hand: on the left margin a list of popular games, on the right side a list of the best streamers.
Naturally, since it is an official YouTube application, you can log into your account. This way, you can like videos, write comments, and broadcast your own videos under your username.
YouTube Gaming is a specially interesting application for video games fans, since it lets you access videos of almost any video game in a matter of seconds.
Tech Specs
- Views: 1,178
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(2 votes, average: 5.00 out of 5) Loading...
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- Android: 4.1 and up
- Version: V184.108.40.206
- Size: 15MB
Download Count
Swipe the video down to return to browse and search, with the gameplay continuing in a smaller screen on the bottom right. Swipe right on the mini viewer to stop watching the live stream. Search for your favorite channel to follow, your favorite game, or scroll through what is live streaming now. You can pause a stream and come back to it, or rewind if you need to see something again or missed something important. While you're watching a live stream, you can chat with other viewers, look at the details, or see more suggested feeds based on the game you are watching.

subset: commoncrawl


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When my father Ira Fulton was just 12 years old, his father stood him in front of a mirror and said, "Ira, this is your competition. Don't compare yourself to others; just compare yourself with you." Years later, my father would repeat this scenario, but now he was the father and I was the mirror image.
On this Father's Day I am thankful for the many lessons my father instilled in me, ones I have passed on to my children. These lessons of hard work, being honest and relying on one's own abilities were implanted in him from his own parents who, like many, struggled through the Great Depression. My father was not handed anything. As a youth he mowed and raked yards, had his own paper route, sold wild honey, built fruit boxes, and washed dishes at his mother's small Tempe café. He earned his way.
I reflected this theme when I was young. I was never given an allowance. It was a privilege to have a roof over my head and food in my stomach. I had to earn my own way. With my father's support, when I was 11 years old I began busing tables at a local eatery called Rosita's Restaurant for $1 an hour. I then made a big career move by taking my dish washing talents to a Golden Dragon restaurant for a whopping 50-cent pay increase.
During this time my father was the head of Eagleson's Big & Tall men's clothiers, then based in Los Angeles. My summer job was to sweep out Eagleson's warehouse for $3.50 an hour. I quickly discovered I could not fool or trick my dad, nor could I loaf on the job. Believe me, as a teen I tried, but he never let me get away with it. I am grateful now for his firm but loving direction. Over time I proved myself, eventually becoming Eagleson's president for seven years.
But while having various jobs as a youth, there was my father's golden thread of advice running through them all: Whatever the job, do it the very best you can. It was ingrained in me to do my best because my name and reputation was attached to it. It doesn't matter if you're sweeping a warehouse or you own the warehouse and everything in it. Your name is on the job; the responsibility is yours. To this day I abide by this axiom.
My father stressed the importance of giving back to the community. As a kid he often saw his mother feeding people at her café who could not pay for food. My grandmother never turned away a hungry person. That example of compassion and taking care of others stuck with my father. He learned the principles of giving, and he passed it on. Over the years Fulton Homes has sponsored many programs, mainly water safety and educational programs. It is our way of paying it forward to others.
Like that mirror image of my father, I did the same for my children. They all had chores to do in our house, whether it was tending to our garden or caring for the menagerie of animals we've had over the years. There are no trust fund babies in the Fulton family. You work honest for what you get, and you reap what you sow. The motto has always been: If you want money, then go make some.
At the end of the day I am grateful because I can look in the mirror and be thankful both for my father's love and guidance and for the image I see reflected back at me.
• Doug Fulton is chief executive officer of Tempe-based Fulton Homes. On rare occasions he still washes dishes at home.


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Saturday's prep highlights: Central, Danville runners shine
In cross-country
■ At Peoria. Led by COREY WHITE (27th place) and ASHTON HYATT (29th), Champaign Central was 10th among 52 teams. Danville was 16th behind JOHNNY LEVERENZ (third) and CALEB HUMMER (seventh).
■ At Springfield. Aleah Combs (88th) and Eduardo Lopez (82nd) paced Rantoul at the Halberg Invite.
In football
■ Fisher 28, Nokomis 20. AARON CARTER rushed for 199 yards and three touchdowns as the unbeaten Bunnies held on. Visiting Fisher, which led 28-6 at the break, rushed for 402 yards. BRAD PETTENGER had 68, TYLER ROGERS 65 and CONRAD THOMAS 60.
"We played with high energy and with momentum," Fisher coach MATT LENG said. "We did a nice job doing what we do, which is run the ball. The defense pursued and swarmed to the ball." JOSH WALLICK had eight tackles. "Josh is our bell cow on the defensive and offensive lines," Leng said.
In golf
■ At Mattoon. LOGAN HANNON had a second-round 77 to finish at 161 for Mahomet-Seymour, which finished an area-best 16th at the Mattoon Invitational. Centennial (17th) was led by CHRISTIAN KHACHATURIAN (157). JT DONAHUE shot 159 for Urbana. CHRIS TATE (163) led St. Thomas More (23rd). RILEY THOMPSON (169) led Champaign Central (25th).
■ At Farmer City. MASON POTTS shot a 75 to finish fourth and lead Blue Ridge to second place at the Blue Ridge Invitational. Teammate CORY JAYNE shot 77. Monticello was fourth behind ZACH FISHER's 86.
■ At Normal. KATIE BROWN's 91 led Centennial to an 11th-place finish at the Normal Community Invite.
In soccer
■ Central 8, St. Thomas More 2. TIM HAM scored three goals and EMMANUEL KOMBA had two goals and an assist as the Maroons pulled away in the second half. FELI KETI had two assists and RYAN CHALIFOUX added a goal and an assist in the win.
■ At Hoopeston. BRENNAN CROSE's goal off an assist from ELIJAH YATES led Hoopeston Area past Blue Ridge 1-0 in the title match at the Cornjerker Classic. TREY ANDERSON posted his fourth shutout for the Cornjerkers (9-1), who went 4-0 in tourney play. CHASE BOUSE and Crose each scored twice in a 5-0 win against Fisher and each scored twice in a 5-1 win against St. Joseph-Ogden. BRYANT ANDERSON's goal led SJ-O past Oakwood 1-0 in the third-place match.
■ Jacksonville 2, Danville 0. CAMERON GRIFFIN had four saves for the visiting Vikings (2-3-3).
■ Normal Community 5, Centennial 0. Despite 11 shots on goal, the visiting Chargers lost in Big 12 play for the first time (2-1).
■ Charleston 5, Mahomet-Seymour 1. LANE SHAFER scored for the host Bulldogs.
■ Unity 5, Decatur Christian 2. MARK GREDY-MYHRE, GRIFFEN BOYER and TREVOR GIANNETTI each had a goal and an assist for the visiting Rockets.
■ At Morton. DAVID ANDERSON scored Urbana's only goal as the Tigers lost 2-1 to Edwardsville and 3-0 to Rochester at the Morton Invitational.
In tennis
■ At Mattoon. Rachael Lewis and BECCA LEWIS won at No. 1 doubles and AMY SHAH and NEHA PATEL won at No. 2 doubles as Danville finished second at the Mattoon Invitational. AMANDA VADEBONCOEUR placed third at No. 2 singles.
■ At Bloomington. TERESA BOERMA was fourth at No. 2 singles and LAUREN NEITZEL was fifth at No. 1 singles for Centennial at the 16-team Bloomington tournament.
In volleyball
■ Westville tournament. Salt Fork, which went 4-0 to finish first, was led by EMILIE McFADDEN (20 kills, 17 digs), KALYN LEARNARD (27 digs), ALLIE TROSPER (51 assists) and BRITTON SEAMAN (seven aces, four blocks). Mariah Rolinitis had eight kills and five aces for 2-2 Westville. Chrisman went 3-1 behind SHELBY WARNER's 11 kills and five blocks.
■ Arthur tournament. KARLY GOODMAN had 21 kills and SHERELLE COLLER had 56 assists as Arthur-Lovington went 4-0 for first place. EMILY SEEGMILLER had 19 aces.
■ Watseka 2, GCMS 0. TAYLOR BAUER and LEXI SHOEMAKER each had nine kills for the Warriors (15-0).
■ At Effingham. Led by all-tourney choice MIAYA PEACOCK, Centennial went 4-1 and finished fifth in the top bracket at the Crossroads Classic. ABBY SMITH had 33 kills as Tri-County went 1-4.
■ At Clinton. GABBY PEARL (29 kills, 10 aces) and AMBER BLAZER (42 kills) were all-tourney as Blue Ridge finished second at the Clinton Invitational.
■ At Mahomet. Led by all-tourney selections MADDIE LeGRANDE and DANA WESTFIELD, Champaign Central placed fourth at the 16-team Mahomet-Seymour Invitational. SJ-O was fifth behind all-tourney pick SHELBY SIMMONS. Urbana placed ninth, and M-S was 11th, getting 57 digs from SIRENA WOO and 96 assists from MASON MOORE.
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You are here: Home / Papers / OECD Digital Economy Papers / Developments in Mobile Termination
OECD Digital Economy Papers
- 2071-6826 (online)
- http://dx.doi.org/10.1787/20716826
The OECD Directorate for Science, Technology and Innovation (STI) undertakes a wide range of activities to better understand how information and communication technologies (ICTs) contribute to sustainable economic growth and social well-being. The OECD Digital Economy Papers series covers a broad range of ICT-related issues and makes selected studies available to a wider readership. They include policy reports, which are officially declassified by an OECD Committee, and occasional working papers, which are meant to share early knowledge.
Developments in Mobile Termination
Click to Access:
- Author(s):
- 28 Feb 2012
- Bibliographic information
- No.:
- 193
- Pages:
- 36
- http://dx.doi.org/10.1787/5k9f97dxnd9r-en
Wholesale interconnection rates for mobile telephony service in the OECD area have decreased by 53% from 2006 to 2011. The charges, or mobile termination rates (MTRs), represent the fees that telecommunication network operators (fixed, mobile and VoIP) pay for delivering telephone calls to mobile wireless providers. Lower rates enable competition in the telecommunications market, encourage greater usage of mobile services through flexible unlimited call plans, and increase overall consumer welfare. Furthermore, it is only in countries where rates are lowest or even at zero that new innovative VoIP services like Google Voice are able to flourish. This report is timely because many regulatory bodies, including in the United States and the European Commission, are debating whether to phase out MTRs altogether.


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Automated external defibrillators of a portable type and accessories, namely, electrodes and battery packs
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Skip to comments.Psychological profiling of terrorists Obama bans the truth to enable more terror
Posted on 04/21/2013 4:48:52 PM PDT by markomalley
There are plenty of psychiatrists / psychologists hired by the Department of Defense, the Department of Homeland Security, the Federal Bureau of Investigation, the Central Intelligence Agency, the Department of Energy, and all sorts of competing agencies of other Federal organizations, not to mention all kinds of military and paramilitary and other kinds of actionable groups.
One of their jobs is to profile the psychology of a terrorist.
But these shrinks are missing the forest for the trees, indeed, for getting caught up in the moss on this or that tree.
Proof of this is their pitiable descriptions of depression, or anger, or being conflicted. A perfect example of this regards a psychologists description of the Muslim military shrink in Fort Hood who shot up his fellow soldiers in an act of terrorism that Obama declared was not terrorism (regardless of that terrorists involvement with known overseas terrorists).
Ooooo! Its all so senseless, so unreasonable, a sign of mental illness, they say.
These guys speak of being radicalized, which they equate with throwing spittle flecked tantrums. But that doesnt speak to reality, does it?
As it turns out, Obama has forbidden profilers to delve into the truth of the matter. They cannot ask, What do Muslims believe? Robert Spencer has a great two page article on this: Page One and Page Two.
In that short article, Robert didnt get around to mentioning, however, a broader point, which involves a perspective on reason from the point of view of Islamic belief. You cant mention everything all the time, but it is the one aspect of all this that few, if any, talk about, and now talking about it, by those who should talk about it, is banned.
This aspect about reason and faith trumps all other aspects of the psychology of this or that individual. Its what sets the stage for radicalization or other things to be successful. Understand this one, central, driving force, and youre way ahead of the game.
Remember Pope Benedicts Regensburg Address, and why it was rejected by all ideological power brokers of Islam? Benedict asked for a dialogue based on reason. Reason in dialogue was explicitly rejected with the statement that our reason is useless, that Allah has a different reasoning than ours. The context of this was the Islamic spreading of faith by the sword, the political edge of Islam without which there is no Islamic belief.
Remember Pope Francis opening volley in dialogue? He recalled that Regensburg Address by asking for a dialogue based on reason. That request is still hanging in the air.
Once a Muslim accepts that there is no reason to be applied to religion, that religion doesnt need to be reasonable, all bets are off. There are no more values anymore, as one of the Boston Marathon bombers said. Whatever Allah wants, thats what Allah gets.
Read those two pages by Robert linked to above.
Whatever Obama says, intelligence community psychologists shouldnt be looking for anyone spittle-flecked. As with most terrorists of this kind, they are as cool as cucumbers, more so than all others around them. Hey! Theres a point for a profile.
At any rate, the younger terrorist is soon to be questioned, if he survives. However, if the best that can be thrown at him is the Reid Technique, theyll get nowhere fast.
Such a terrorist is not interested in claiming innocence. He will immediately say that he did what he did and proclaim that Allah is great. Theres no way to embarrass someone who proclaims that there are no values because reason is useless in the face of belief in Allah.
Sure, the Reid Technique is subtle, and can trick information out of someone, and perhaps questions about family and friends back in the old country and the refugee camp will bear some fruit. But, I would say, almost none.
I suppose that is why some Senators want this fellow to be called an enemy combatant. Military interrogators, I would think, have learned that the Reid Technique is basically useless for Islamic terrorists.
I can already hear the objections to this post. Before objecting, read the two pages of Robert linked to above. I agree with what he has to say.
Terrorists can be easily subdivided into Jihadi terrorists and Infidel terrorists.
"Army Major (Hasan) Played Role in Presidential (Obama) Transition"
"What difference does it make?"
"Freedom is never more than one generation away from extinction.
We didn't pass it to our children in the bloodstream.
It must be fought for, protected, and handed on for them to do the same,
or one day we will spend our sunset years telling our children
and our children's children what it was once like in the United States where men were free."
President Ronald Reagan
There are plenty of psychiatrists / psychologists hired by the Department of Defense, the Department of Homeland Security, the Federal Bureau of Investigation, the Central Intelligence Agency, the Department of Energy, and all sorts of competing agencies of other Federal organizations, not to mention all kinds of military and paramilitary and other kinds of actionable groups.
Yeah, like Maj. Nidal Malik Hasan.
Their high usage of force availed them little. The elder poordeprived child was killed by the tires of the younger poordeprived child's stolen SUV and the younger one was ratted out by an observant homeowner. All of the hundreds of expended rounds produced a couple of hits on the targeted gentlemen. Perhaps a billion or more $$$ of lost commerce and wages and ammo and gear to catch two perps who were not very skilled in e&e and who lost out to other forces.
Disclaimer: Opinions posted on Free Republic are those of the individual posters and do not necessarily represent the opinion of Free Republic or its management. All materials posted herein are protected by copyright law and the exemption for fair use of copyrighted works.


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- select colour
it's an internet thing!
it's an internet thing!
15:08 21 July 2009
To scare yourself silly it's unlikely that gamers would turn to the Nintendo Wii for satisfaction.
With the exception of a handful of titles, such as 'Resident Evil', there isnt really much on offer for horror game fans.
But judging by Deep Silver's forthcoming title for the 'family friendly' console, it is exactly where to go for a frightening experience.
'Cursed Mountain' is a survival horror game set in the 80s where gamers take on the role of a fearless mountaineer who climbs into the Himalayas searching for his lost brother.
On his journey he stumbles upon an ancient curse and encounters many lost souls who died in the area and are stuck in limbo - enter hordes of dead but not yet resting villagers, pilgrims, mountaineers and Buddhist monks.
Annihilating the living dead isnt the only thing that has gamers excited about this mystery-thriller title. It's the unusual trailer hype that has many shaking in their socks.
Take a look at the reactions of those who have been lucky enough to sample 'Cursed Mountain' pre release.
%%youtube http://www.youtube.com/watch?v=CzcRJmhwLWA
Complete with eerie music and crisp graphics, 'Cursed Mountain' certainly seems to be one of the most advanced looking games on the Wii.
The visual detail of the Himalayas, the weather and lighting provide a detail that many games on the console are lacking.
The living dead are also terrifying especially the Monks (pictured above) from which the game bases its themes upon Buddhist and Tibetan myths.
'Cursed Mountain' is set to be released across the UK on September 4.
But if you can't wait until then check out the official website here or watch the full trailer and more scare clips here.
Disclaimer: Supanet is not responsible for, and disclaims any and all liability for the content of comments written by contributors to this website


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A niece pays tribute to her uncle who was murdered, in this short documentary.
Directed by Carolyn Wong
A man was murdered. He was a son, brother and uncle. Although remembered for his many accolades, Howard was in fact embroiled in an existential conflict that resulted in his self-destructive behavior. Howard is Howard's niece's attempt to collect the vestiges of his past, in tribute to his memory.
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Rise in staff attacks at Oberstown youth facility as gardai continue search for three teen escapees
A shocking 31 staff members working in the Oberstown facility for young offenders in Dublin received serious injuries following violent incidents at the centre in the past four months.
The worrying rise in attacks on staff come as gardai continue to search for three escapees who broke out of the facility last week.
Staff are hugely concerned about the rise in assaults following the recent transfer of older offenders to the centre, which has resulted in workers been forced to take stress-related sick leave.
The warnings are contained in a briefing document compiled by the Oireachtas Health Committee and sent to Children's Minister James Reilly.
Members of the Health Committee recently met with Oberstown staff to discuss their concerns about working conditions at the centre.
Following the meeting, Committee chairman Jerry Buttimer wrote to Mr Reilly outlining staff concerns.
Workers warned that the facility was not prepared for introduction of older offenders who are "physically bigger, older and exhibit more challenging behaviour".
Staff say this has "changed the dynamic" between staff and the younger boys.
They warned that most staff do not have sufficient training to deal the increasing number of violent incidents.
In the letter, seen by Independent.ie, the Health Committee said it was concerned that there was no "sanctions or consequences" for offenders who threaten or assault staff.
The committee also noted that there was no system in place to separate the older, more violent offenders, from the younger boys.
It was also noted that the new facility was contributing to the rise in aggressive behaviour.
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text:
Waterloo Road
2006, 10 seasons to date
By Ann McManus
Latest Episodes
Show more
Season 1 Show All Episodes
Episode 1: Episode #1.1Acting head-teacher Jack Rimmer hires Oxbridge graduate Andr...Mar 9, 2006
Episode 2: Episode #1.2Adam's sister Yasmin holds Donte responsible for her brother...Mar 16, 2006
Episode #1.3
Jack has to make it clear to Steph that their one-off was down to his being drunk,though he sees she is a good teacher,even inspiring slacker Lewis. Jack,however,has a bigger problem when 15-year old Zoe starts school,claiming that he is the father of her unborn child. After Jack has had a heart to heart with Tom it becomes evident that the timing precludes his being the father and Zoe admits she was put up to it by the real father,a boy Jack expelled. Tom reconciles with Lorna for a romantic dinner,only to learn she has miscarried whilst Chlo feels she should admit ...553431125
Episode #1.4
Headmaster Jack is still regretting his night of passion with flirty French teacher Steph, but is pleasantly surprised when her class improves its grades. Meanwhile, Chlo is terrified she and her boyfriend Donte will end up behind bars for the crash that killed their friend Adam. As the drama continues, the pupils think its hilarious when a fluffy bunny climbs onto the roof of the school. But Izzie is mortified when she realises its her ex-husband, Jimmy. He wants access to his kids and he's not getting down until she agrees. Tom's suspicions about Lorna's miscarriage...186738127
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Season 2 Show All Episodes
Episode 1: Episode #2.1Former pupil and local entrepreneur Roger Aspinall offers fi...Jan 14, 2007
Episode 2: Episode #2.2Andrew is a disaster as acting head,suspending popular Janee...Jan 21, 2007
Episode #2.3
Jack reinstates Grantly,making it clear that he has no desire to be part of Aspinall's plans. At the same time Davina is shocked to find that Brett is still at school as they had previously has a brief fling and she thought he was older. Andrew and Lorna,who now has her own flat and seems more secure,start dating but the hate campaign against Mika ends up with her attempting suicide before a contrite Leigh-Ann reconciles with her. Chlo sneaks out to have sex with Donte,but is followed by Seddon.686219158
Episode #2.4
Seddon robs Donte but Donte,armed with a spanner,persuades him to return his belongings. Davina is still pursued by a love-lorn Brett,whose behaviour gives cause for concern but whose academic record is good for the school league tables. Ultimately Brett confesses that he hates his father for having an affair whilst his mother was dying but the father and son eventually reconcile. Jack finally gets one over on Aspinall when he discovers his funding comes from a porn website. Whilst Lorna is suffering from dizzy spells Steph is mugged by drug-addicted ex-pupil Maxine ...41102084
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Season 3 Show All Episodes
Episode 1: Episode #3.1Though given a bravery award Jack blames himself for Izzie's...Oct 11, 2007
Episode 2: Episode #3.2Whilst Davina makes progress with Karla Jasmine is concerned...Oct 18, 2007
Episode #3.3
Donte goes behind Chlo's back to put down a deposit on a dilapidated flat. Chlo is less than pleased and Tom persuades them to stay with him. Jasmine has trouble controlling an unruly class and puts half of them in detention. Unfortunately they comprise the girls' football team,due to play their debut match. Eddie persuades Jasmine to postpone the detention to facilitate the match but Jasmine herself saves the day by passing herself off as a pupil and playing in the match,scoring the necessary goals. Matt is annoyed that Steph is taking over the musical,giving the ...237816222
Episode #3.4
When pupil Ben McNulty cuts himself Steph immediately rushes him to hospital and it transpires that she knows he is HIV+,due to his drug-taking birth mother but has kept the fact a secret. There is an immediate backlash by angry parents,as a result of which Ben decides to quit the school. However Jack's resolute championing of Ben and efforts to persuade him to stay impress Davina and they get engaged. Steph,who has high hopes after their spot of passion,turns to Matt for consolation,only to learn that he is gay and has a partner called Colin. Donte and Chlo return to...823045137
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Season 4 Show All Episodes
Episode 1: Episode #4.1Having survived the fire Rachel starts a new term having to...Jan 7, 2009
Episode 2: Episode #4.2Melissa has discipline problems due to disruptive Rose Kelly...Jan 14, 2009
Episode #4.3
When Maori supply teacher Maaka Lacey makes a homophobic comment Davina reports him to Rachel but he counters by accusing her of racism. However his lazy attitude in sending disruptive pupils he cannot control on pointless errands backfires when it causes a fight between Tom and Earl Kelly and he is sacked. Elsewhere Steph finds herself playing landlady to Grantly,whose wife believed her little lie that they are an item and threw him out ,whilst Tom is troubled to find a dead bird on his door-step.809731133
Episode #4.4
Steph reconciles Grantly and his wife before agreeing to a date with Dave. Following a visit to a falconry display Earl Kelly vehemently denies killing birds and leaving them on Tom's step but his sensible,older brother Marley tells Tom that he is lying. The war of attrition steps up between teacher and crazy pupil as Tom finds Earl vandalizing his car one night. Maxine,however,develops a crush on Marley,which unsettles Steph.182317211
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Season 5 Show All Episodes
Episode 1: Episode #5.1Waterloo Road is forged to merge with John Fosters,a former...Oct 28, 2009
Episode 2: Episode #5.2The animosity between the new colleagues continues. Grantly...Nov 4, 2009
Episode #5.3
Kim and Max share a night of passion which they must keep secret from Rachel. Lindsay,angry that her mother is not bailed for killing the father she hated,goes off the rails,attacking Karla,who has befriended Emily. Tom is brought down to earth when he meets Georgia,who confirms his paternity of Josh. Danielle and Aleesha get drunk and Steph hides Danielle in a cupboard during an assessment,rather than report her. Later Danielle is rushed to hospital after drinking bootleg hooch made by Bolton and Paul from ethanol. She survives but Jo tells Steph that she is the ...39862879
Episode #5.4
Pupil Luke Pendle has kept it secret that he lives in a care home but his girlfriend Siobhan,suspicious that he keeps his home life secret,follows him and finds out. She confides in Amy,who informs the whole school,leading to Luke going on the rampage,for which Max gives him litter collecting duties. After another row Luke steals and crashes Max's car but Kim urges the executive head to be understanding and not call the police. He is also thwarted when,behind Rachel's back,he tries to float a scheme splitting students into groups according to their ability,and Grantly...762619125
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Season 6 Show All Episodes
Episode 1: Episode #6.1New head Karen Fisher replaces Rachel and new language teach...Sep 1, 2010
Episode 2: Episode #6.2Ruby,now cured of her medication habit,reunites with husband...Sep 2, 2010
Episode #6.3
Karen instigates a sexual health initiative with a confidential contraceptive service. Students Ronan and Sarah are concerned as the condom broke whilst they were having sex but she is nervous about attending and asking for the morning after pill. So too is Jess for fear that her promiscuous life-style will be exposed so she sends Vicki to get it for her. However the ruse is discovered and the girls argue in front of Chris. He is concerned for Jess's welfare but she misreads it as being rather more,given her crush on him.746924226
Episode #6.4
Whilst Karen insists on marking the birthday of Bex,the daughter who ran away from home,Charlie and Jess believe it is morbid. Connor Lewis,an openly gay pupil,arrives and whilst Josh is rude to him,he later attempts to kiss Finn,leading to a fight. However he denies any such thing when brought before Tom and tries to compensate by getting physical with a confused Lauren. Vicki finds it hard juggling looking after her sick father and tries to blackmail Chris into giving her better grades after Jess has told her about their one-night stand. Janeece suggests that the ...62834493
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Season 7 Show All Episodes
Episode 1: Episode #7.1Headteacher Ms Fisher deals with abandoned infant found on s...May 4, 2011
Episode 2: Episode #7.2Finn is back,bullying withdrawn Martin Dunbar,who is caught...May 11, 2011
Episode #7.3
Amy discovers she has a stalker,who turns out to be shy,asthmatic Stuart Foley,whom Eleanor advises to stand up to his bullying father. Eleanor organizes a project where the sixth-formers film themselves but it ends in disaster. Finn and Josh break the uninsured camera and Stuart uses it to expose his father's affair with Amy's mother,leading to Karen disciplining Eleanor. Sambucca has filmed herself explaining she has terminal cancer but it is only seen by a tearful Finn. Janeece gives Daniel a make-over whilst Rob,as well as warning Aiden to behave himself with the ...219729229
Episode #7.4
New pupil Evie Prior has trouble fitting in and when Finn sticks up for her Sambucca's friends accuse Evie of trying to steal him. Ultimately Evie confesses to Chris that she is really Alicia Cross,under police protection for killing her toddler cousin but the revelation of her secret means she has to move on. Whilst Aiden,romancing Jess,is seeing Vicki behind Ronan's back,his father goes on a date with Karen after she has helped him with an essay. This fact is picked up by Eleanor,angry with Karen who,she feels,underrates her and who makes Karen aware she knows what ...101337273
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Season 8 Show All Episodes
Episode 1: New BeginningsDedicated to Denzil,killed by the drunken lorry driver who p...Aug 23, 2012
Episode 2: Spirit ChildMichael's efforts to call a truce with Gerard Findlay are vi...Aug 30, 2012
Troubled Waters
As the feud between Havelock,Gerard Findlay's school,and Waterloo Road continues Findlay posts twenty-five year old press cuttings around the school describing how the young Michael Byrne attacked his father and left him for dead. The two heads confront each other and Findlay slips whilst trying to hit Michael,who later confesses to Sian that he had only been defending his mother against his violent father. Tariq grows more despairing about his handicap and engineers a fight between ex-Havelock pupil Angus Hancock and Phoenix,to create a diversion during which he ...597027287
Read My Lips
Imogen Stewart, a hearing-impaired student is embarrassed when her flirtatious mother Sally arrives to take charge of a sponsored rowing marathon to buy Tariq a kayak. Sally gate-crashes Imogen's birthday party ,where she and Angus are found in a state of undress in a bedroom though,when Sally explains her guilt over her view that she caused Imogen's deafness following a bout of meningitis there is some understanding reached. Fort Connor,however,whilst getting close to Imogen,things only get worse as he gets drunk and torches the basement. Whilst he is not caught for ...10694282
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Season 9 Show All Episodes
Episode 1: Beyond the Call of DutyThe school is still mourning the death of Tom, especially Ka...Sep 5, 2013
Episode 2: Sue Spark's Bad DaySeizing on her inability to keep order pupils led by Rhianno...Sep 12, 2013
The Madness of King Windsor
Simon plans the school's own version of 'The Apprentice', pitting girls against boys and financing it himself when Christine tries to cancel it due to budget cuts. The girls go in for selling cakes, the boys for selling unwanted household items donated. Barry Barry tries to sabotage the girls but Grantly comes to their aid and they win. Innocently believing Lisa has turned over a new leaf Audrey is blissfully unaware that Moira, a friend she has met online, is actually Lisa herself. Princess feels exploited by George and kisses Kevin when he comes to her house to ...290220288
Text Rated
George discovers that Princess is planning to leave him to work in London. He tries to thwart her but Kevin helps her to escape. Given a make-over by Dynasty Rhiannon asks new boy Darren Hughes to an upcoming dance, sending a revealing picture of herself to his phone. Barry Barry bullies him into sending it online and Rhiannon is mortified but Dynasty organizes revenge by photographing Darren and Barry in the shower. Christine steps in, demanding all photos be deleted and announcing that any similar future action will involve the police. The dance goes ahead with ...927640217
- +See All
Season 10 Show All Episodes
Episode 1: Home Sweet HomeWith Christine demoted a new head teacher arrives - Vaughan...Oct 15, 2014
Episode 2: One Good TurnVaughan encourages the students to offer their services to m...Oct 22, 2014
Baby Boom
Allie starts a virtual baby scheme to teach pupils parenting skills but few of them take it seriously. One exception is Rhiannon, who confesses to the understanding Harley that she may be pregnant. Darren is less than sympathetic and, although the pregnancy test proves negative, she ends the relationship when she sees how shallow she is. She is consoled by Maggie, who suggests a career working with children. Carol stages a kitchen accident in the hopes of suing the school but is thwarted by Vaughan, who sacks her ,whilst Tiffany attempts to get through to Justin.471110254
Pool Party
Gabriella Wark returns to school from therapy, a far gentler person, though she encounters general hostility from most of the staff and pupils, except Rhiannon and Allie's children, whom she invites to her house in her parents' absence. The vindictive Shaznay and Lisa alert dozens of students to the house and chaos ensues, with the two nasty girls trashing Gabriella's dead sister's room. A fight breaks out and Gabriella is knocked unconscious and falls into the swimming pool, from where she is rescued by Kacey. Sue and Hector are summoned and order the gate crashers ...783820189
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text:
Silky Dogwood
Cornus obliqua
Foliage Color:
Bloom Characteristics:
Water Requirements:
Requires consistently moist soil; do not let dry out between waterings
Where to Grow:
Grow outdoors year-round
6-8 ft. (1.8-2.4 m)
8-10 ft. (2.4-3 m)
10-12 ft. (3-3.6 m)
4-6 ft. (1.2-1.8 m)
6-8 ft. (1.8-2.4 m)
8-10 ft. (2.4-3 m)
10-12 ft. (3-3.6 m)
USDA Zone 4a: to -34.4 �C (-30 �F)
USDA Zone 4b: to -31.6 �C (-25 �F)
USDA Zone 5a: to -28.8 �C (-20 �F)
USDA Zone 5b: to -26.1 �C (-15 �F)
USDA Zone 6a: to -23.3 �C (-10 �F)
USDA Zone 6b: to -20.5 �C (-5 �F)
USDA Zone 7a: to -17.7 �C (0 �F)
USDA Zone 7b: to -14.9 �C (5 �F)
USDA Zone 8a: to -12.2 �C (10 �F)
USDA Zone 8b: to -9.4 �C (15 �F)
Sun Exposure:
Full Sun
Sun to Partial Shade
Bloom Color:
White/Near White
Bloom Time:
Late Spring/Early Summer
Good Fall Color
Other details:
Soil pH requirements:
6.1 to 6.5 (mildly acidic)
6.6 to 7.5 (neutral)
Patent Information:
Propagation Methods:
Seed Collecting:
This plant has been said to grow in the following regions:
Lisle, Illinois
Chesterton, Indiana
Hopkinton, Massachusetts
Leesburg, Virginia
Gardeners' Notes:
On Jul 25, 2016, Rickwebb from Downingtown, PA wrote:
There is some confusion over this species or variety that is called Narrowleaved or Swamp or Pale Dogwood. Some consider it as a separate species and others as a variety of the Silky Dogwood of Cornus ammomum. In other words, Cornus ammomum obliqua. I favor the latter, as there is so little difference. This variety has slightly smaller leaves that are narrower of 2 to 4" long x 1/2 to 1.25 inches wide while the regular Silky Dogwood has leaves 2 to 5" x 3/4 to 2.5 inches wide. The hairs under the leaves and on twigs are not rusty like the regular Silky Dogwood. Otherwise, these shrubs get about 6 to 12 feet high, bear flattish white flower clusters in late spring, bear fruit that goes from green to white to blue, and both get purplish-red fall color whether dull or brighter.


text:
Nora Silver 20W 2700K 40 Degree PAR38 LED Rear Loading Gimbal Ring Track Head
Product Info
Line voltage PAR adjustable gimbal ring fixture. White finished housing holds lamp socket, allowing PAR lamp to clip directly into the adjustable gimbal ring. A steel yoke holds the gimbal ring in place and allows for full lateral aiming adjustment. Single tightening knob assures secure lock on angle position.
Average Rated Life (hr): 25000
Beam Angle (deg): 40
Bulb: LED PAR38
Bulb Wattage: 20
Color: Silver
ColorTemp: 2700
Diameter (in): 5 in.
Length: 6 in.
--> Nora Lighting - NT301 Silver 2 ft. Single Circuit Track
--> Nora Lighting - NT303 Silver 6 ft. Single Circuit Track
--> Nora Lighting - NT304 Silver 8 ft. Single Circuit Track
Be the first to review our Nora Lighting Silver 20W 2700K 40 Degree PAR38 LED Gimbal Ring Track Head


text:
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Is it still cold and dreary outside? Brighten your days with an easy-to-make arrangement of fresh flowers. Gather an odd number of old or new More
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Tips from the Kitchen Getting Garlic Smell off of Your Fingers Three words: salt, lemon, steel. One way to remove the odor is to rub More


text:
Macau Casino Woes Prompt Deutsche Bank Downgrades, Price Target Cuts
Slowing demand from gamblers in Macau and and intensifying competition for their yuan lead Deutsche Bank to downgrade leading players in the sector Friday while slashing targets across the board.
Deutsche's Karen Tang also cited rising labor costs and longer times for approval required for new facilities.
Tang downgraded the Macau unit of Wynn Resorts (NASDAQ: WYNN) to Sell from Hold and moved her rating on the China Sands unit of Las Vegas Sands (NYSE: LVS) to Hold from Buy.
Both units trade on the Hong Kong stock exchange. Wynn Macau fell 3.3 percent Friday morning; China Sands lost 0.4 percent.
Macau, the world's largest gambling center, is the only place in China where casinos are legal and revenues have declined lately in the face of that country's economic slowdown, as well as a crackdown on corruption that has so far resulted in the reported arrest of more than 60,000.
As if to add insult to injury, local authorities will impose a smoking ban starting October 6 on Macau's mass-market gaming floors.
High-end private VIP gaming rooms are exempt, but China's smoking rate is nearly 70 percent higher than the United States.
In addition, Tang made the following target cuts: Galaxy Entertainment (OTC: GXYEY) $61.50 from $80; Melco Crown Entertainment (NASDAQ: MPEL) $29.03 from $41; MGM China (OTC: MCHVY) $27 from $32 and SJM Holdings (OTC: SJMHF) $20.05 from $21.50.
Latest Ratings for WYNN
|Oct 2017
|Oct 2017
|Stifel Nicolaus
|Oct 2017
|Roth Capital
|Initiates Coverage On
View More Analyst Ratings for WYNN
View the Latest Analyst Ratings
Posted-In: Deutsche Bank Karen TangDowngrades Price Target Analyst Ratings
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