In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for March 2020.

Some of the highlights include:

  1. Portugal Freezes Assets of Africa’s Richest Woman-could this be even bigger than 1 MDB?
  2. Thoughts on Teva FCPA enforcement action in the context of it completing its DPA.
  3. What is the DOJ saying around FCPA enforcement in the Covid-19 era?
  4. What significance, if any, do you see in Mexico request to extradite former Pemex official?
  5. OECD Expresses Concern over Costa Rica’s Foreign Bribery Enforcement Record. What does this mean?


To a copy of the Top 10 International Anti-Corruption Developments for March 2020 Newsletter click here.

In this episode of Trekking Through Compliance, we consider the episode Let That Be Your Last Battlefield which aired on January 10, 1969, Star Date 5730.2.

Story Synopsis

The Federation starship Enterprise is on a mission to help decontaminate the polluted atmosphere of the planet Ariannus, when sensors detect a Federation shuttlecraft that was reported stolen. The craft is brought aboard along with its alien pilot, who identifies himself as Lokai, a political refugee from the planet Cheron. Lokai’s most striking feature is that his skin is black on one side of his body and white on the other side and he claims to be a political refugee from Cheron.

Shortly thereafter, sensors detect another spacecraft in pursuit of the Enterprise. The alien craft destroys itself, but not before its pilot, Bele, transports to the Enterprise bridge. He is colored black and white, similar to Lokai. Bele explains that he is on a mission to retrieve political traitors. His current quarry is Lokai, whom he has been chasing for 50,000 Earth years. Bele is taken to Lokai, and the two begin to argue about the history of their peoples, almost coming to blows.

Bele demands that Captain Kirk take him and Lokai to Cheron. Kirk refuses, telling him he will have to make his case to Federation authorities. Sometime later, the ship changes course to Cheron, and Bele announces that his “will” has taken control of the ship. Lokai demands the death of Bele, and Kirk orders both of them to be taken to the brig. Unfortunately, a force field generated by both aliens makes that impossible. With no other way to regain control, Kirk threatens to destroy the Enterprise, and begins the ship’s auto-destruct sequence. In the last seconds of the countdown Bele relents, and the ship resumes its course to Ariannus.

As Bele continues angrily to press his matter with Starfleet, he reveals the source of his conflict with Lokai. He, and all of his people on Cheron, are black on their right sides, while Lokai’s people are all white on their right sides. The distinction is lost on the ship’s officers, who leave it for legal authorities at the next Starbase to decide. Once the Ariannus mission is completed, Bele takes control of the Enterprise again, this time disabling the self-destruct system. When the ship arrives at Cheron, Spock can find no sign of intelligent life. Lokai and Bele realize they are each the only ones left of their peoples. Enraged, they attack each other, their force fields threatening to damage the ship. Lokai breaks away, Bele pursues him, and the two eventually beam down to the planet.

Fun Fact 

According to the Memory Alpha listing this episode, the original story concept did not depict the aliens with bi-colored skin. Fred Freiberger recalled, “Gene Coon originally had a devil with a tail chasing an angel.” Episode director Jud Taylor came up with the idea of bi-colored skin shortly before the episode began filming. His original suggestion was that they be half-black/half-white, one color from the waist up and the other from the waist down, but each wearing reversed color schemes. The central idea stuck but the colors were finally separated along the vertical axis rather than along the horizontal.

Compliance Takeaways:

  1. Why language translation is so important.
  2. The role of compliance in creating safe work places.
  3. Why should you do business with ethical companies?


Excruciatingly Detailed Plot Summary by Eric W. Weisstein for Let That Be Your Last Battlefield That Be Your Last Battlefield

Memory Alpha –Let That Be Your Last Battlefield

In this episode of Trekking Through Compliance, we consider the episode Whom Gods Destroy which aired on January 3, 1969, Star Date 5718.3.

Story Synopsis

Kirk and Spock beam down to Elba II to deliver a revolutionary medicine to the insane asylum located there which houses the 15 incorrigible insane criminals of the Federation. Elba II is surrounded by a poisonous atmosphere. Inmate Marta warns Kirk and Spock that their host is not really governor Donald Cory, but they do not believe her. Upon viewing Cory’s cell, however, Kirk and Spock discover that the inmate and former starship fleet captain Garth of Isar has imprisoned Cory in his cell and is running the facility with the aid of the other inmates. Garth imprisons Kirk with Cory and destroys the medicines Kirk and Spock have brought.

Garth is able to change form at will using the technique of cellular metamorphosis and attempts to gain control of the Enterprise to escape and punish his former mutinous crew by impersonating Kirk. Garth is thwarted by the password Kirk has arranged with Scotty when Scotty queries “queen to queen’s level 3” and Garth does not know the proper response to this problem in 3-D chess: “queen to king’s level 1.”

Garth then invites Kirk to dinner with the inmates and Mr. Spock. At the banquet, the green poet inmate Marta recites Shakespeare and performs an exotic dance, which Spock find similar to a dance performed by Vulcan school children. We find out that Garth has charted more new worlds than any man in history, but then tried to destroy Antos 4. When Kirk refuses to reveal the counter password, Garth tortures Cory in a specially modified therapeutic chair. When Kirk still refuses, he is strapped in and tortured.

However, Marta convinces Garth to let her try more persuasive techniques. She begins making love to Kirk, then attacks him with a knife. She has arranged for Spock to be freed, and he luckily steps in and nerve pinches her before she can stab Kirk. Kirk and Spock make it to the control room where they contact the Enterprise. However, Kirk smells a rat, and demands that Spock give the countersign instead of himself. Spock, who is actually Garth in disguise, then puts the force field back on and assumes his true form before a security team can be beamed down. Kirk attempts to turn the force field back off, but is stunned by Garth before he can do so.

Garth then holds a ceremony in which he declares himself ruler of the universe, Marta his consort, and Kirk his heir apparent. He then threatens to use a powerful new explosive he has invented on Marta, who is dragged out into the poisonous atmosphere. Garth then carries out his threat, and commands that Spock be brought in. Spock pretends to be knocked out in his cell, then nerve pinches the two guards who have come to fetch him. He makes his way to the control room, where he is confronted by what appear to be two identical Captain Kirks. Spock tries to distinguish the real from the impostor by asking what maneuver was used to defeat the Romulan ship near Tau Ceti. One Kirk correctly gives the maneuver as the Cochrane deceleration, but the other Kirk points out that this is a classic battle maneuver. The two Kirks then have it out, and Spock is able to identify Garth when the real Kirk tells Spock to stun them both in order to assure the safety of the Enterprise. Control of the institution is returned to Cory, and Garth and his colleagues are cured using the new drugs. 

Fun Fact 

According to an interview published in Star Trek Lives Leonard Nimoy complained about discrepancies in the script, including inconsistencies in his own character. He blamed the director for making changes in the script to focus on “action” rather than on intelligent problem-solving, and felt the changes were a form of lying to the audience. He also complained about Spock not being able to tell the difference between the real Kirk from the impostor. Nimoy sent the memo to both producer Fred Freiberger and Paramount Television executive in charge of production, Douglas S. Cramer.

Compliance Takeaways:

  1. Do you have audit rights and do you exercise them?
  2. High risk does not mean you cannot move forward, it means you must have a robust risk management strategy.
  3. Do you go with facts or your gut in decision making?


Excruciatingly Detailed Plot Summary by Eric W. Weisstein for Whom Gods Destroy Gods Destroy

In this episode of Trekking Through Compliance, we consider the episode Elan of Troyius which aired on December 20, 1968, Star Date 4372.5.

Story Synopsis

The Enterprise is on a top-secret mission to the Tellun star system. It takes aboard Petri, ambassador from Troyius, then continues on the the inner planet Elaas. Here it beams aboard three Elaasian guards who check that all is secure, then the haughty Dohlman of Elaas. Kirk is surprised by her bearing, she demands that Kirk and everyone else, whom she calls inferior, ask her permission to enter and leave her presence. Petri explains that Elaan is to be taken to Troyius for a marriage with the ruler of Troyius in order to stop a bloody war. The Elaasian Council of Nobles and Troyius Tribunal have agreed that Petri shall teach Elaan the customs of Troyius where are the barest rudiments of civilized behavior, but Elaan has other ideas. She also complains and hurls things about the room when she is unsatisfied with her quarters.

At Petri’s request, Kirk proceeds on to the return trip on impulse engines only so as to allow plenty of time for Elaan’s “education.” Not surprisingly, the lessons do not go well, and Elaan stabs Petri in the back with a knife. To make matters worse, the Federation commissioner sends a coded signal to the Enterprise that he plans to attend the wedding personally.

Meanwhile, Spock detects a “ghost” paralleling the Enterprise’s course. After fading in and out of sensor range, it finally ventures closer and reveals itself to be a Klingon warship. The reason for the presence of the Klingon warship turns out to be that the Elaasian guard Kriton, is in love with Elaan and has thrown in with the Klingons in a fierce jealousy over having to give up Elaan to the Troyian leader. Kriton booby-traps the warp engines, killing an engineer who discovers and tries to question him.

Kirk tries to take over the tutoring but doesn’t get much further than Petri and has a knife thrown at him. Despite Elaan’s orders to the contrary, Kirk enters her chamber (after Spock stuns the two guards) and attempts to administer another lesson. At first, Elaan tries again to kill him. She then locks herself in a closet and tells Kirk that she will wait there 10 “light-years” if she has to, but then has a change of heart. She cries and tells Kirk she wants to make people like her. Kirk unwisely touches her tears, which contain a biochemical substance which causes men to fall in love with them and is snared.

Kriton transmits a signal to the Klingon ship using a Klingon communicator, but is then caught. Before Spock can use the Vulcan mind meld on him, he uses a concealed phaser to commit suicide. The Klingon ship then heads for the Enterprise at warp speed. Luckily, just before Kirk gives orders to maneuver, Scott discovers that the matter-antimatter pods are rigged to explode as soon as the Enterprise goes to warp speed. The Klingon ship streaks by the Enterprise without firing, presumably waiting for it to go to light speed and blow itself up. Unfortunately, Scott finds that the dilithium crystals have been completely fused, and that power for the warp drive and phasers is therefore not available. The Klingons demand that the Enterprise prepare to be boarded or destroyed. When Kirk does not comply, the Klingon attacks.

Spock has been wondering why the Klingons are interested in Elaan in the first place, but discovers the reason when Elaan comes to the bridge and bridge sensors show that the “common stones” in the Dohlman’s necklace are made of dilithium crystals. Scotty is able to effect repairs to the engines using the crystals, and Kirk blows up the Klingon using photon torpedoes on its next pass. Kirk is able to resist the effects of the tears and to McCoy’s annoyance, since he has actually managed to find an antidote, and the Dohlman is transported safely to Troyius.

Fun Fact 

From a comment by jayoungr on, cited below “The “Taming of the Shrew” and Helen of Troy aspects of the episode are obvious, but I wonder if the overtones of Tristan and Isolde were deliberate. They meet when Tristan goes to escort Isolde to marry his king, and they fall in love after accidentally drinking a love potion on the way.”

Compliance Takeaways:

  1. Do you perform continuous monitoring of your 3rdparties?
  2. How deep does your 3rdparty investigation go?
  3. How culturally astute is your compliance regime?


Excruciatingly Detailed Plot Summary by Eric W. Weisstein for Elan of Troyius of Troyius