The Sting in the Deal:
What Every Buyer & Seller Must
Know About the FCPA
April 15, 2010
Sponsored by:
The Sting in the Deal –
What Every Buyer and Seller Must
Know About the Foreign Corrupt Practices Act
Discussion Leader
Jonathan Marks, CPA, CFF, CFE
Partner In-Charge of Fraud & Ethics
212.572.5576 or jonathan.marks@crowehorwath.com
http://www.linkedin.com/in/jonathantmarks
Panel
Jonathan Marks, CPA, CFE, CFF
• Partner In-Charge of Fraud & Ethics at Crowe Horwath LLP
Gregory Paw
• Attorney engaged in Foreign Corrupt Practices Act matters at
Pepper Hamilton LLP
Matthew Tanzer
• VP and Chief Compliance Counsel, Tyco International
Kathleen Hamann
• Trial Attorney, U.S. Department of Justice, Criminal Division,
Fraud Section
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Siemens: $2.6 Billion
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Others Impacted
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Real World?
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
6
Why Anti-Corruption Compliance Is Important
• Increased Enforcement
• Number of investigations is on the rise!
• Increased Penalties
• Penalties are up significantly from prior years
• Individual Enforcement
• DOJ and SEC are increasingly targeting executives; sentences
include jail time
• Increasing cooperation and coordination
internationally
• 38 countries have adopted OECD Convention on Combating
Bribery of Foreign Public Officials in International Business
• Some countries aggressively enforcing
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Why Anti-Corruption Compliance Is Important
• Voluntary disclosure is increasing
• DOJ and SEC are encouraging companies to voluntarily disclose
issues
• Almost 2/3 of the disclosed FCPA investigations in 2005-2007 were
voluntarily disclosed to the SEC
• Government settlements are also requiring external
monitors to ensure compliance
• 2- and 3-year monitors are becoming a standard part of
settlements
• The annual cost of external monitors can range from $1 to $3+
million per year
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Why Anti-Corruption Compliance Is Important
• Increase in M&A
• FCPA-related due diligence is leading to voluntary disclosures
• SOX certification and internal controls
• Increased expectations of Board of Directors and
Audit Committees – possibility of personal liability
• World governmental attitudes changing
• Many other countries are cracking down on bribery
• Cross country cooperation
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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And One More Reason…
Target Industries
• Technology
• Oil and Gas
• Manufacturing
• Engineering and
Construction
• Pharmaceutical
• Medical Devices
• Mining
• Transportation
Source: Transparency International
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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FCPA Fundamentals
1. Anti-Bribery Provision
• Makes it illegal to make payments with a corrupt motive directly or
indirectly, to foreign officials, officials of foreign political parties, or
any other person acting as a conduit for payments to foreign
officials or political parties for the purpose of influencing the official,
in order to assist in obtaining/retaining business
2. Books and Records Provision
• Requires companies who file reports with the SEC to maintain
records that accurately reflect transactions and the nature and
quantity of corporate assets and liabilities
3. Other Key Facts
• Ignorance of the law is not a valid defense
• Source of the alleged bribe does not have to be in the U.S.
• Actions of an agent acting “on behalf” of a company are attributed
to company
• Actions of the foreign sub will be attributed to the U.S. parent
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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5 Elements Constituting a Violation
Who
Corrupt Intent
Payment
• Potentially applies
to any individual,
firm, officer,
director,
employee, or
agent of the firm
and any
stockholder acting
on behalf of the
firm
• Person making or
authorizing the
payment must
have corrupt intent
• Prohibits paying,
offering or
promising to pay,
authorizing
payment of money
or anything of
value
• Includes foreign
subsidiaries,
affiliates and joint
ventures
• Payment must be
intended to
prompt the
recipient to misuse
his official position
to act or fail to act
• Offer of a corrupt
payment can
constitute a
violation even if
unsuccessful
Recipient
• A foreign official
• A foreign political
party or party
official
• Any candidate for
foreign political
office
• Includes certain
government
entities,
international
governmental
organizations,
advisors, or
consultants to
foreign
governments
Business Purpose
Test
• Payment must be
made to a
decision-maker for
the purpose of:
i. Influencing,
inducing or
otherwise
affecting an
official act,
decision or
omission
thereof,
ii. Securing an
improper
advantage, or
iii. Assisting in
obtaining or
retaining
business for
any person or
entity
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Sanctions Against Noncompliance
Criminal Sanctions
• Business entities are subject to a fine up
to $2 million per violation.
Violating
Antibribery
Provisions
Violating
Accounting
Provisions
• Officers, directors, employees, and
agents of the firm can face fine up
$250,000 and/or five years imprisonment
per violation.*
• Business entities may be fined up to $25
million.
• Employees that knowingly violate the
provisions are subject to $5 million in fines
and 20 years imprisonment.*
Enforced by the Department of Justice
Civil Sanctions
• For both business entities and
individuals, a civil action for a fine
$10,000 may be levied for violations.*
• For both business entities and
individuals, a court may impose an
additional fine not to exceed the greater of
(i) the amount of gain as a result of the
violation or (ii) a specified dollar amount.*
• Business entities can be subject to civil
penalties ranging from $50,000 to
$500,000.
• For individuals, a civil action for a fine up
to $100,000 may be levied for violations.*
Enforced by the SEC
(and DOJ in rare circumstances)
* Fines levied against individuals may not be paid by their employer or principal
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
13
M&A Anti-Corruption Issues
• Pre-acquisition due diligence
• Successor liability
• Vicarious liability
• Controlling Interest
• Compliance programs
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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M&A: Pre-Acquisition Due Diligence
• Private firm Latin Node, Inc. had a number of
contracts with state-run telephone companies in
Honduras and Yemen
• In 2007, eLandia
International, Inc.
acquired Latin Node for
over $26 million
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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M&A: The Other Shoe Drops
• Shortly after purchase, eLandia discovered bribery
scheme to obtain contracts, and reported to the SEC
• Latin Node entered guilty plea to FCPA offenses, paid
$2 million fine
• eLandia reported it
overpaid by $20.6
million for the true
value of Latin Node
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Private Equity: The Impact of Corruption
• “Pirate of Prague” Viktor Kozeny led
an effort in late 1990s to invest in
and privatize SOCAR, the state oil
company of Azerbaijan
• Handbag magnate Frederic Bourke was part of a
group of private equity investors that included
Omega Advisors, Inc. and AIG
• Prosecutors charge that Kozeny led his bid with
offers of bribes to Azerbaijani officials
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Private Equity: Criminal Liability?
• Clayton Lewis, Omega employee, allegedly was told
by Kozeny about bribes to secure SOCAR bid
• Pled guilty to FCPA offenses, awaiting sentencing
• Omega Advisors
• Agreed to cooperation agreement and $500,000 civil forfeiture
• Frederic Bourke allegedly turned “blind eye” and
kept “head in the sand” about Kozeny’s actions
• Convicted at trial, sentenced to 1 year and 1 day imprisonment, on
appeal
• David Pinkerton, AIG
• Indicted but charges dropped
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Private Equity: ABB/Vetco/Aibel
• In 2004, private equity group led by JP Morgan sought to
purchase ABB/Vetco. Two Vetco units had pending FCPA
charges.
• Release 2004-02: Justice approves procedures before sale,
emphasizing importance of compliance program.
• Vetco/Aibel sold again to private equity, and more FCPA issues
emerge.
• Early 2007, 3 years later, three Vetco units pled to FCPA
offenses and paid $26 million fine. Aibel also agreed to
compliance reforms
• Agreement took into account compliance failures, as well as new
sale, new compliance efforts and self-disclosure
• Late 2008, Aibel enters plea to FCPA offenses and pays $4.2
million fine
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Lessons Learned
• Pre-acquisition due diligence
• Vibrant compliance program
• Timely post-acquisition review / compliance
• Self audits
• Periodic reevaluations
• Remedial steps
• Self reporting of violations
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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What is Effective Due Diligence?
• Tailor due diligence based on risk of business being
acquired
• What is the nature of the business
• Where are they conducting business
• Who are the key players and with whom are they conducting
business
• Due diligence should address
• Use of agents and other third parties
• Commercial dealings with state-owned customers
• Joint venture, teaming or consortium arrangements
• Customs and immigration matters
• Tax matters
• Any government licenses and permits
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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What is Effective Due Diligence?
• Consider external counsel and consultants, including
forensic accountants, to conduct the due diligence
• Obtain representations and warrantees from seller
• Implement contractual protections
• Covenants, representations and warranties
• Audit rights
• Suspension/termination rights
• Confidentiality provision allowing pre-acquisition disclosure
• Document due diligence steps
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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10 Steps to Minimizing FCPA Risk
1. Ensure commitment and accountability of senior
management
2. Include FCPA in corporate code of conduct
3. Establish FCPA policy guidelines including clear
approval guidelines for disbursements
4. Review FCPA-related internal controls to ensure
you are properly flagging high-risk areas of your
business
5. Use all available tools to conduct internal audits of
FCPA controls, records and payments made by
foreign affiliates
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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10 Steps to Minimizing FCPA Risk
(continued)
6. Investigate when red flags or bribery allegations
arise
7. Understand corruption risk in countries where
business is being done (see Transparency
International’s CPI)
8. Include FCPA language in contracts and
agreements including right to audit
9. Ensure periodic training of relevant employees
10. Perform proper due diligence on foreign business
partners
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Intangible Benefits of Anti-Corruption Efforts
• For example, in Iraq, the United Nations Oil-for-Food
Program became corrupted
• Massive surcharge and kickback scheme
• 139 companies pay oil surcharge
• 2,250 companies pay kickbacks
• Over $1.4 billion diverted to Iraq government
through payment of “Inland Transportation Fees” and
“After-Sales Service Fees”
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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Follow the Money
• Over $1.4 billion diverted from “humanitarian”
purposes
• Diverted to Ministries of Defense and Military
Industrialization, as well as intelligence services
• Used to buy trucks, tires, batteries, even date palm
excavators
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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At the Scene
Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or
liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any
other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
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ACG Philadelphia Cup
Business Case Competition
Sponsored by:
ACG Philadelphia Cup Judges
Co-Chairs
• Michael Bailey, Argosy Private Equity
• Barbara Shander, Morgan Lewis & Bockius
Judges Committee
• Scott Heery, KPMG
• Mitchell Hollin, LLR Partners
• Ken Jones, Boathouse Capital
• Mike McAleer, KPMG
• Joe McGinley, Comcast Corporation
• Andrew Panzo, NewSpring Capital Partners
Sponsored by:
ACG Philadelphia Cup Finalists
Drexel University, LeBow College of
Business
Ryan Baker
Paul Green
Robert Lodge
Scott Freeman
Temple University, Fox School of
Business
Qiyi Bao
Michael Ettinger
Vijay Iyer
Shao Zhang
La Salle University School of Business
Birad Bhatt
Justin Solomon
Mikael Vincke
The Wharton School of the University
of Pennsylvania
Deb Bardham
Uttam Jain
Aditya Joshi
Nikhil Kirtane
TzerHan Lim
Fabio Salvagni
Penn State University, Smeal College
of Business
Jonathan Wesner
Xiaoyu Zhang
Howard Ho
Tieming Lang
Sponsored by:
ACG Philadelphia Cup
2nd Place Team
Villanova University School of Business
Meet Doshi
Patrick Doherty
Olivia Pietrunti
Sumedha Verma
Sponsored by:
ACG Philadelphia Cup
1st Place Team
St. Joseph’s University, Haub School of
Business
Chris Frystock
Jan Bartczak
Sponsored by:
Mark Your Calendar for 2010 Events
Upcoming Events
May 5 - 6, 2010
ACG InterGrowth
Miami, FL
May 20, 2010
Lenders’ Panel Discussion: Joint Program with TMA Philadelphia
June 3, 2010
Corporate Buyers Dinner Discussion (Invitation Only to Strategic Buyers)
June 17, 2010
The Honorable David M. Walker, Former US Controller
July 12, 2010
Annual ACG Member Guest Golf Outing Huntingdon Valley Country Club