I bribed foreign officials, I cooperated with international law enforcement, and I went to prison. Having that experience behind me, I am now extremely grateful for the opportunity to write, both on my blog and as a guest on other sites, about my experiences and perspectives concerning compliance challenges from the front line of international business. However, my path to getting to where I can now take such opportunities to share with others was filled with many ups and downs. I hope that even those struggles, too, might benefit others. While I remain grateful that the worst part of this experience for myself and my family, including the loss of liberty, remain in the rear view mirror, I always manage to keep an eye on that mirror, as not to forget the path, and the humility, which brought me to the place where today, I can share my experience with others.
During the many years when I was working in the field of international sales, I was aware that I was engaging in illegal behavior. However, at that time in my life, I wasn’t thinking about getting caught and did not think I would get caught. I was well educated, well paid, and in a very respected position, with respect to both compensation and recognition, in my career. So why break the law? Well, as I have shared, and here I again point out, I discuss this not in terms of justification, but in the context of how I “rationalized bribery.” In my case, it was a perfect storm, where a number of factors came together, all which I talk about extensively in my presentations and writings.
When I did get caught in 2007 (by my former employer), it was a frightening moment, to say the least. I was alone facing a panel of attorneys and seasoned investigators. Of course, the first consequence that comes to mind in a situation like that is the loss of my job and income. It didn’t take long to calculate that I would be terminated in the near future, so I started thinking about the financial consequences to my family.
The second “getting caught” point for me was by far more significant. It was at this point that I truly hit bottom and started on my trajectory of rehabilitation, which continues to this day. It started in the spring of 2007 with a call from the Justice Department to my attorney, Brady Toensing. They said they knew about the investigation by my then, former employer, and they offered to let us come in and Proffer.It is really difficult to articulate the intensity of the Proffer experience. But I realized that, as described by DOJ Attorney Joey Lipton (at my sentencing), this was my “line in the sand.” No matter what happened up until that first Proffer meeting, this was a chance to truly come clean with my misdeeds. For me, the process of cooperating with the government, which started with this first meeting, also allowed me to re-think how I had been living, and to start the healing process with my family and friends.
My proffer initiated a period cooperation with US and UK law enforcement, which lasted five years, including almost three years of covert cooperation (one of the longest periods of covert cooperation in Federal Law Enforcement) and two years of preparation for trial testimony and actual testimony, including three calendar weeks of cross-examination. While there has been a great deal of reporting about my cooperation, and the outcome of the cases where I was a cooperator, as I reflect on this period of my life, I am happy to be back with my family, friends and community. As I will share, it was ultimately Judge Leon (District Judge, DC) who would weigh the value of my cooperation, and he would have sole authority to judge the significance my cooperation against the magnitude of my illegal conduct, which I candidly admitted to in my court testimony.
Judge Leon understood the seriousness of my illegal conduct, the value of my cooperation, as well as my personal and professional efforts to contribute to society since the ending of my covert cooperation. When he weighed all of that, which I think of as the “good, bad and ugly,” he decided that a sentence was still warranted. I am at peace with his decision, and I served my time with dignity as well as “productively” (as Judge Leon stated at sentencing), providing value to others in their educational goals as a GED and ESL tutor. Naturally, I will continue to try to make amends for my conduct for the rest of my life by investing my time with family and friends, and trying to make a positive contribution to society through my continued community service, both court ordered and elective.
As I now reflect, I realize how I lost sight of the importance of strong family and personal relationships during the years of conduct to which I pleaded guilty. My dedication to those bonds, which was once extremely strong in my life, had been replaced with the never-ending want and accumulation of material things. “Getting caught” by the government stopped that downward spiral in my life and set me back on a course toward reconnecting with what is truly important in life and on a path of reconciliation. Thus, as I today share my experience with others, both personally and professionally, I do my best to discuss the ups and downs of my journey, so that people might understand that success built on a corrupt foundation, is no success at all; whereas, if someone is willing to tear down such a foundation and to rebuild, that it is indeed never too late to set off on a new, healthier trajectory.