FOR IMMEDIATE RELEASE Contact Nick Schwellenbach , 202-347-1122
POGO: Project On Government Oversight
Leaked Audit: Manufacturers and FAA Allowing Defective Parts on Planes
Insufficient Oversight of Foreign and Domestic Outsourcing

Washington, D. C. –The Project On Government Oversight has obtained a Transportation Department Inspector General (IG) report dated February 26, 2008 and not yet released to the public, which finds
that "neither manufacturers nor FAA inspectors have provided effective oversight of suppliers; this has allowed substandard parts to enter the aviation supply chain." (Page 4) These suppliers include those that provide parts critical for safe flight on both civilian and military aircraft. The audit found that outsourcing to
other countries is a significant safety oversight concern, reminiscent of regulatory failures of foreign-made products, such as that of drug safety and quality by the FDA and of consumer products.

However, even domestically, the Federal Aviation Administration and major aerospace companies failed on a massive scale to ensure quality control. http://www.pogoarchives.org/m/tr/faa-supplier-20080226.pdf

"A massive effort must be made to beef up the entire aviation safety oversight apparatus—lives and billions of dollars are at stake," said Nick Schwellenbach , a POGO investigator. "This is further proof that
the FAA continues to be a captured agency, offering just a fig leaf of ineffective regulation at the public's peril. And manufacturers continue to put short-term profit ahead of proven and prudent safety
and quality."

Three of the numerous examples cited in the report are as follows:

• "Manufacturers were not verifying that their suppliers were providing effective oversight of the sub-tier suppliers they used to produce parts. This is a critical safety issue, as demonstrated by four engine failures that occurred in FY 2003 due to faulty speed sensors on fuel pumps obtained from a supplier. Three of the engine failures occurred on the ground and one occurred in flight. The part failures were traced to unapproved design changes made by a sub-tier supplier. In all, 152 parts were manufactured in the suspect population." (Page 12)

• "Effective oversight of suppliers is essential to ensure that substandard parts do not enter the aviation supply chain. For example, in February 2003, 1 supplier released approximately 5,000 parts that were not manufactured properly for use on landing gear for large commercial passenger aircraft. At least one of these landing gear parts failed while in service. While FAA became aware of this large-scale breakdown at this supplier in 2003, it has not performed a supplier audit at this facility in the last 4 years." (Page 11)

• "One supplier allowed new, untrained employees to manufacture several components. We witnessed one new employee improperly inspecting a product. A later review of his training record showed that he had not received any formal training in the proper inspection method. This was the same supplier mentioned previously that used a piece of paper as a measuring device for an oil and fuel pressure
transmitter." (Page 13) Controls," he added.

The IG audit examined supplier oversight at Boeing, Bombardier/Learjet, General Electric Aircraft Engines, Rolls-Royce, Pratt & Whitney, and Airbus, as well as at the FAA, the government agency responsible for ensuring aviation safety.

In the audit obtained by POGO , the IG found in 20 out of 21 suppliers that there were "widespread deficiencies at supplier facilities used by major aviation manufacturers. We found that some aircraft manufacturers had not designed effective oversight systems for their aircraft part suppliers." (Page 4) The IG added, "Manufacturers are the first line of defense in ensuring the products used on their aircraft meet FAA and manufacturers' standards. Yet, during the 24 months preceding our review, manufacturers had not audited 6 of the 21 critical part suppliers we visited." (Page 5)

The "second line of defense"—FAA oversight—was found grossly insufficient for a variety of reasons. For example, regardless of the number of suppliers an aviation manufacturer has, the FAA only has to perform four audits a year of its suppliers. The IG stated that "a manufacturer that has 2,000 suppliers and is assessed as a high risk will require the same number of supplier audits as a high-risk manufacturer that has only 20 suppliers." (Page 8) To further illustrate, "for 2 consecutive years, FAA scheduled the maximum of four supplier audits for a manufacturer of agricultural aircraft (i.e., crop dusters). Conversely, for one of these years, another FAA inspector did not perform any supplier audits for a major engine manufacturer for commercial aircraft." (Page 8)

Furthermore, according to the audit, the number of FAA supplier audits has declined even as the issue of supplier oversight has been identified as one of six top issues in aviation manufacturing.

An inverted set of incentives has been created under the FAA's new "risk-based" inspection system, implemented in 2003. One Manufacturing Inspection District Office manager told the IG that "his inspector workload had been cut almost in half under the new risk-based system." (Page 7) Another anager "changed the results of the statistical sample because he did not have sufficient travel funds to complete audits of the selected foreign suppliers. The manager instructed inspectors to select suppliers in their local area in place of the foreign suppliers." (Pages 7-8)

In a striking statistic, the IG stated "in each of the last 4 years, FAA has inspected an average of 1 percent of the total suppliers used by the five manufacturers we reviewed. At FAA's current surveillance
rate, it would take inspectors at least 98 years to audit every supplier once. This is particularly troubling because, as discussed previously, manufacturers are not evaluating these suppliers frequently or comprehensively." (Page 9)

In 2000, the IG stated in a report on manufacturers' quality assurance systems for fasteners—which led to the report of quality control systems in general that POGO obtained—that evidence suggested a "systemic weakness in FAA's process to evaluate safety issues brought to the agency's attention." (Page 4 of
http://www.oig.dot.gov/StreamFile?file=/data/pdfdocs/av2001003.pdf)

POGO will continue to investigate these issues and urge Congress to hold hearings.
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Founded in 1981, the Project On Government Oversight ( POGO ) is an independent nonprofit that investigates and exposes corruption in order to achieve a more accountable federal government.

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Gerald Eastman's Court Date is fast approaching.

With all of the disclosures of corruption involving his former employer, The Boeing Company, and federal oversight agency FAA, new attention to his allegations of Boeing and FAA wrongdoing is
warranted. (See his site at: www.thelastinspector.com)
What do you do when every avenue open to you within the hierarchy of your contractor employer is a dead end to straightening out wrongdoing you observed going on in your work area, and supervisors?

When in following prescribed channels, you go up the command chain in your company and find that your company not only condones, but also might have been directing your seemingly corrupt supervisors in those problem activities? You go to the federal oversight authority, the Federal Aviation Administration.

And if the FAA, itself is so corrupted you cannot get the problems addressed and rectified? You keep trying, multiples of times. And if that still doesn't work? You go above FAA to Department of Transportation (DOT) Office of Inspector General. And if you can't get anyone there to cross the corrupt ones? What can a formerly loyal TBC employee (quality assurance inspector) and honest person do if every avenue of redress is corrupted and manipulated? Some might, in desperation, consider going to the
media, particularly if the person was aware that there might be a big safety risk to the flying public and military users of the company's aircraft.

A person with a moral base, and a conscience that won't just let him blow it off and look the other way, as many advised him to do to avoid being targeted and destroyed by the very company he had loyally
worked for, might try to turn some lights on in the swamp. Think about it. In the current atmosphere of corruption coming from the highest levels of our government, it could well be you, any of you
who work in defense or other government contractors, or in government agencies. In the opinion of this observer more investigations into the business practices of Boeing and the FAA/DOT and the legally
enforced ending of harassment of Boeing and FAA whistleblowers must be done. –GFS

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Ex-Boeing worker accused of leaking sensitive documents
Story Published: Jul 10, 2007 at 3:00 PM PST
By Associated Press

SEATTLE (AP) - A former Boeing Co. worker accused of downloading sensitive internal documents and leaking them to the media was charged Tuesday with 16 counts of computer trespass.

Gerald Lee Eastman was arrested in May 2006, briefly held in jail and subsequently fired from his job as a quality assurance inspector in Boeing's Seattle-based propulsion division, the company confirmed.

In a statement of probable cause, a Seattle police detective said Eastman downloaded hundreds of thousands of pages of documents that contained information he did not have authorization to access and
shared some of it with reporters at The Seattle Times and the Seattle Post-Intelligencer.

Police said Eastman told investigators he "was disgruntled with the Boeing Company because he had brought several issues related to inspection of parts to the company, and to the (Federal Aviation
Administration).

"He contended that none of his concerns were addressed to his satisfaction by either the company or the FAA, and that he continued to try to get his concerns heard and rectified to his satisfaction," court documents said.

Boeing spokesman Tim Neale countered, "We always take those types of allegations seriously and have processes in place to follow them up."

Walt Gillette, vice president of airplane development for Boeing's 787 program, estimated that the leaks could potentially cost Boeing $5 billion to $15 billion, court documents said.

Neale said he could not confirm whether Boeing had suffered any actual losses as a result of the leaks, and noted the case prompted changes in the company's security system.

"We have tightened our security system so that in today's environment someone could not obtain sensitive documents in the same manner he did," Neale said.

Eastman is scheduled to be arraigned Monday. He faces a standard range of about three and a half years to nearly five years in prison if convicted on all counts.

This page can be used by those companies and corporations wondering how they can be successful at skirting laws and regulations even if your organization has "paid the price" after being caught by any of the few ethical government agencies in existence for corrupt activities in the past, or, much more preferably, can be used to learn what not to do to keep your corporation from going down the paths of using corruption to meet your organization's goals and/or to cover up and continue your misdeeds rather than actually ending them and becoming a truly ethical company:

1. First of all, attitude is everything, as they say, and to continue and/or cover up corruption in your organization--especially widespread and endemic corruption that has been in your organization for years and would be much more difficult (for financial and other reasons) to end than to continue--you must have the correct corporate attitude to make your corrupt activities have the most positive impact on the bottom line and to keep them secret to the extent possible for them to continue. This is not the image in your public image ad campaigns. This is the real attitude of your corporation, and it must come from your corporate headquarters and flow down through the organization and be made known to those outside the company that may (through ethical "defects") feel obligated to report corruption within your company they have learned about to any of the the local, state, or federal government agencies. It is the "attitude" your own "in the know" employees know, and anyone daring to expose your corruption from within the company or from without must be made to know and fear. The most preferred attitude in this regard for your corporation to have would be extreme arrogance. Arrogance lets those people that might otherwise dare to expose your corruption know that you do not care what the public or what the government really knows about your corporation's corruption. They know through your arrogant "behind the scenes" corporate attitude and related actions that you will roll right over anyone who gets in the way of any sort of corrupt activity your corporation chooses to engage in. Make people fear the size and power of your organization to make their lives miserable if they so much as think of holding you accountable for any illegal or unethical action you are engaged in or are contemplating engaging in. They will get the message if your corporation projects this sort of attitude successfully. Boeing is a good example in this regard. As noted elsewhere on this site, a Corporate Investigations Manager told me (in an interview with him the day after I was released from jail in my own personal lesson of Boeing's arrogance) that "Boeing is the most arrogant company on the face of the planet." I, personally, because of my intimate experience with Boeing, agree with his matter of factly stated statement. While, per this Boeing manager, Boeing has the #1 position locked up, your corporation could follow this example and set a goal to become the #2 most arrogant company on face of the planet. Arrogance has a key benefit for those organizations wanting to continue or to perpetrate corruption. As I read a former Congressman had sagely said--"arrogance breeds corruption." So, arrogance will not only protect your ability to perform your fraudulent action of choice, that attitude will also foster the corruption you want in your organization, for potentially significant benefits to the bottom line if you succeed in getting away with your fraud of choice.

2. Don't let past negative quarters of financial results when caught and fined for illegal actions deter you from your continuing arrogance and corruption. Just because you were caught on some of the more minor acts of corruption of your company does not mean you have to abandon all corrupt activities within your organization. To do so would have long term negative financial impacts. Even politicians that railed against and even exposed your corruption need not be a deterent. During election seasons and times of weightier issues such as war, your corrupt organization can effectively "skate under the radar" of these same politicians that were pains in your organization's "corrupt backside" before, even if people report some of your remaining and even vastly more serious corrupt activities than you were caught engaging in directly to them. They cannot respond to every report of corporate corruption they get, and they also don't want to be seen as having a vendetta against you, especially if you are a sufficiently powerful corporation and it is election season again. They may have ended a minute part of your corrupt activities in the past, but they may not want to take the risk of taking away from their successful record in the public eye by risking losing the next battle to expose and end reported corruption in your huge and powerful corporation.

3. Become a duopoly in your markets of choice. This will make it impossible for politicians and government agencies to put you and your endemic corrupt activities out of business. If they have a need for your products and services, they will not be able to apply the necessary sanctions that will motivate you to end your corruption and therefore protect the public and military personnel from your corruption. Politicians can then hide behind the bogus reason that contracts with your corrupt organization cannot be effectively ended due to the need for your products and services for national and economic security reasons to excuse them from having to do the tough work of fielding and responding to effectively the numerous reports of corruption such politicians receive about your corpration's corrupt activities by those do-gooders who delude themselves that they can have an effect in ending some part of you enterprise's corrupt activities by reporting them to the seemingly appropriate politician or government agency. This I saw in some of the questions/comments of some of the few politicians who showed up at the 8/1/06 Boeing Tanker/EELV Global Settlement Agreement hearing. Of course such reasons to not go after corrupt corporations are false--the government can hold a company--even one of a duopoly of companies--accountable for their illegal actions while still holding the company to their contract committments to deliver conforming hardware and services. The government can strip such a company (via fines for their actions) of all of their profits for decades to come or until they choose to really end corruption as a primary tool to meet internal financial goals. In addition they can throw any number of corrupt managers of such a corporation in prison (after a fair trial, of course) for any length of time without harming the companies ability to deliver conforming and safe products until managers who get the message that corruption in that company will not be tolerated--truly ethical management--is put in place at the company replacing the imprisoned executives and managers. But that would require a level of oversight by the government that it may not be willing or able to perform because of the endemic and vast nature of your corruption, much to your corrupt company's benefit, of course.

4. Whatever you do, do not start a so called "ethics program" at your company in an attempt to make it seem publicly like you are an ethical company despite your continuing use of massive levels of unethical and illegal acts to meet financial and other goals. While a good PR move, such programs will be expensive and non-value added at a company as corrupt as yours. This is because you dare not let most employees know of your official and unwritten policy of using whatever method, legal or not, best maximizes your bottom line because, in an organization of your size, even the very small percentage of employees that are "ethically defective" (from your corrupt organization's perspective) and would report this fraud to the relevant investigative agency of the government would be a large number of such reports indeed, each with some miniscule risk to your corporation's continued unbridled corrupt activities. These risks and the legal and administrative costs of ending such valid reports of your corporation's wrongdoing by any means makes letting everyone in your organization know about your unwritten policy to use illegal and unethical means to attain business goals a non starter. Therefore, since most employees cannot be told the real way your company does business, such an ethics program would receive massive numbers of reports of the unethical conduct you wish to foster in your company from those employees who actually delude themselves into thinking you want them to follow written but just for PR purposes policies for employees to report unethical and/or illegal conduct at the company if they see such behavior. And even though such a program would be set up to ensure it does not threaten the fraud you wish to engage in by ensuring such reported activities are always dubbed "unsubstantiated" after a psuedo-investigation of the report, such a ethics program would entail significant costs just due to the number of reports from employees who delude themselves that the company is serious about the ethics program--costs that would subtract from your company's all important bottom line and therefore from the potential value of your stock grants and options.

5. However, if you are required to set up some kind of ethics program as promised corrective action to a government entity after having the misfortune of being caught by them for one of your many acts of corruption, you will need to set an ethics program befitting your company (a corrupt one). It is better and much less expensive to set up an ethics program than it would be to have real corrective action that may actually end your use of unethical and illegal acts to maximize the bottom line, such as significant fines that would wipe a whole year's profits off the books and cause your stock price to plummet for years to come. By all means "promise" to set up an ethics program as an alternative to jail sentences for most of the executive management involved in the corruption (especially yourself) and such significant fines, and hope the government "bites" on your proposal, no matter how many times you have been caught breaking such promises in the past. Just carefully avoid "promising" to implement an effective one, if at all possible. A model program would protect your unethical management by deeming the vast majority of ethical complaints against management as "unsubstantiated," no matter how much evidence the person or persons reporting the unethical conduct have of the manager's misconduct. A good standard to apply is to require a video or audio or email trail in order to substatiate such a complaint. As video and audio recording without approval inside most companies is prohibited by company policy and/or privacy laws, that only leaves email as a threat to your corrupt management, and your managers can be warned not to document your company's questionably if not illegal conduct in email, and be told to delete any possible incriminating email ASAP. Of course, you can substantiate claims against non-management personnel as you wish, as those personnel are expendable, and you can use those substantiated claims to give the appearance to the government that your ethics program is working, should they audit the program. A good model for an ethics program for your company can be found here:

Ethics at Boeing?

6. Once your corrupt enterprise is up and running as noted above, it will be important to start banking on that corruption to enhance your bottom line. A key advantage to being a corrupt enterprise are the abilities your corporation has that other "ethically challenged" (ethically challenged, that is, because they behave ethically and you would never limit your corporation that way) do not have--legal, regulatory, and ethical boundaries an ethical company faces mean nothing to your corporation. Just don't get caught stepping across any of those boundaries by the odd ethical government agency or law enforcement agency. Your corporation is arrogant as a necessity, but that does not mean you have to be stupid. In fact, availing your corporation of the ability to cross legal, ethical, and regulatory "lines" is a smart thing to do to ensure winning in the marketplace, especially if you don't get caught doing it.

7. First among things to do to ensure the success of your corrupt enterprise is to ensure that you reduce the chances you get caught and held liable for your actions to a minimum. This is a no brainer, but if you are a slow CEO and gained your position more by who you were born to and/or who you know than what you know, I will spell it out for you: you must begin by corrupting the very agencies that would threaten your corrupt activities to reduce the chances you'll get caught for your crimes and misdemeanors to a minimum. This is easy, and does not require bribing everyone in an agency--just a few key players in the agency that could stifle the agency from rightly acting against your corruption if they are brought into the corrupt fold of your corporation. You need not actually bribe these officials at the time of their services in hamstringing their agencies from acting against your corruption. That would be riskier than need be as a mechanism already exists to bribe these officials "legally." These officials in high positions of authority in their agencies as a rule have many years of service to their agencies, and so are very near or at their retirement ages. Most of them communicate regularly with your management in the course of their oversight functions. During these communications, make it a point to show the government official a company executive's lifestyle--their million dollar home in a gated community, their yacht, the expensive private school or college their children attend. Have the person communicating with this person casually mention that they like the government official's penchant for "working with the company" as opposed to taking enforcement actions against the company that they could have performed. Have your executive contact with this official say that they know the official wants to retire in a few years, and state that a position will be available at your company when they retire that will pay enough they can have all of what you have shown them of your executive's lifestyle and more. Have your person tell them that the position will be there as long as they maintain a friendly "working together" relationship with the company during their last few years in government service, and avoid any enforcement action against your company. These government officials are so underpaid they will bite on this promised executive lifestyle in a heartbeat, and will be effectively in your company's employ from that point on, even though their quid pro quo employment with your company won't actually occur until a few years later. Make a priority list in risk areas for your company to decide which officials to thusly approach and corrupt first to enable maximum payoff for your company's corrupt activities, then just work down the list. Of course, this isn't entirely legal, but as long as the promise of employment is not recorded, you are home free. Officials going directly from government service to the same company they regulated is often done, and though some people ("the ethically challenged" ones) don't like it, it is perfectly legal, except for the way your company does it to corrupt those officials before they leave their agencies, but that is only really known between the corrupt government official and your company. Once you gain a "beachhead" in a government agency like this, it will be easy to get the corrupt government official to promote and groom replacements to act in your corrupt company's best interests in similar quid pro quo arrangements, making the corrupt relationship between your corporation and the government agency truly a self-perpetuating "revolving door" mechanism of corruption that will render that potentially problematic agency to your illegal plans effectively toothless, ad infinitum. This method will work not only with officials in oversight agencies, but for officials in procurement agencies in government as well. It is key to defang and corrupt as many agencies in government as possible in this way before you get seriously and massively involved in your planned bottom line enhancing corrupt activities, for obvious reasons. There are many corporations that have done this successfully, even after being caught in specific instances of thusly improperly influencing government officials. It is these most arrogant of corporations that you should model your corrupt enterprise's activities after.

8. The next thing you will need as an arrogant and corrupt corporation is a legal department that echoes those values. Being a corrupt company using illegal acts to enhance the bottom line will inevitably bring your company many more legal challenges than an ethical company that followed the laws and regulations would face. You'll need to staff up your legal department accordingly, however this extra cost of doing business need not by far eat into your ill gotten bottom line gains. Selecting legal department staffers that can obstruct, forestall, and use esoteric and highly technical legal maneuvers to get even to most rock solid cases against your company dismissed is your goal. The key thing to foster in your company's legal department is the same arrogance and greed and disrespect for the laws and regulations on which your true business plan is based. You must screen potential legal staffers closely, just as you would your ethics department "investigators" (if you are unfortunate enough to be forced into having a psuedo-ethics department). People that are motivated by money and have little or no empathy for others (like some serial killers' lack of empathy) would be ideal candidates not only for management, but for your legal department as well. They must be people that treat the company's money as if it were coming out of their own pockets, so it would be a good idea to compensate these employees by small percentages of potential company liability they avoided by hook or by crook. Compensating employees for particularly imaginatory ways that derail the many valid lawsuits your corrupt company will face is also a good idea, as these methods they come up with can be used again and again on the same similar cases that will inevitably come up when your company thumbs its nose at complying with anything except bottom line, stock price, and executive stock option and grant goals. And, even though your budget for your legal department will be many millions of dollars, that will be a small percentage of the valid claims such a legal department will save your company from paying by any method, both legal and not.

But the greatest function of your legal department will not be to save your corrupt company the millions if not billions of damages you would have to pay if your company owned up to your "sins"--its greatest function will be to keep your arse out of prison, where you deep down know it belongs no matter how jaded you have become, and instead, keep you out on the golf course and otherwise enjoying your CEO kingly lifestyle any way you please. While many would exchange their meager lifestyle (such as the underpaid employees on the lower rungs of the company's and its subcontractor's pay ranges) for yours if they got to live nine tenths of their lives with gold spoons in their mouths and had to spend the last tenth paying for the crimes that got them that lifestyle by being someone's "bitch" in prison for the last tenth of their lives, you obviously don't want to go there ever, or for that matter, ever pay for any of your misdeeds in any way whatsoever--you instead want, of course, those misdeeds to pay you, and to pay you very handsomely indeed.

So, the legal department's highest priority will be to protect you and other members of the board from any legal consequences for your actions, even if the legal consequences are just meaningless labels attached to you and your company, such as being branded a felonious company by having to cop to a few felony charges for the corporation, even though noone on the board does any time and the company just pays a miniscule fine as related to the size of your bottom line. Your legal department must understand these priorities, and must always sacrifice the company and its employees before ever having to offer up your freedom, money, stock options, excessive retirement benefits, or "good name" as part of any legal negotiations.

One good example of a legal department to emulate would be that of the Boeing Company, which has been spectacularly successful in getting the company off with mere taps on the wrists despite being caught a few times "sneaking their hand in the cookie jar" of corruption in order to win competitions for contracts. (What you have to wonder, however, is, considering the amount of times they have been caught, how many times they "stole cookies from under grandma's nose" without being caught before and between the times they were caught, and whether they are still "stealing cookies" today. This site, however, will answer those questions to your satisfaction, if you read enough of it), Take the Druyun Tanker procurement crimes and the Lockheed data theft crimes that the company's legal department negotiated the legal consequences of to the company. For all of the fraud involved in those crimes, the company paid only $50 million dollars in fines, and admitted no criminal wrongdoing. The rest of the $615 million they paid was for actual damages the government suffered because of these crimes.

That's analogous to us making about 55,000 dollars a year (about one millionth of Boeing's annual revenues), having our children go into a bank and rob it, getting 25,000 dollars from the heist (about one millionth of the value of the contracts Boeing stole because of these affairs that were settled for the $50 million, plus actual damages), being caught as a family red handed in the act of the robbery, and not being arrested, but instead, the police that caught you in the act let your family go home unhindered with the cash while they investigate, while you negotiate from the luxury of home with them for a couple years before reaching an agreement.

And the agreement (consequences to you of robbing the bank) would be that you agree to let your children be prosecuted for the bank robbery even though your "win (steal) at any cost" parenting told them to rob the bank for you, you have to give the bank back the money, you have to pay a 50 dollar penalty, you have no charges brought against you (the mastermind of the robbery) for the robbery in court, and also, you do not have to admit guilt yourself for robbing the bank either. It would be just as if you hadn't robbed the bank at all, except for the 50 dollars you were out, and your children perhaps doing time for your crimes. Do you think you could rob a bank and get that kind of deal? Me neither. That is why it would pay for your corrupt corporation to have a legal department like Boeing has.

As a side note, it was rumored in the press that Boeing was facing $750 million in fines (unknown as to how much of that was for actual damages the government suffered and fhow much was a penalty for the crimes) and was going to be required to plead guilty to at least two felony counts as a company. That is rumored to be what the career (not appointed to office by the president) Justice department employees had stood their ground for, when the political apointees in the Justice department stepped in (one of which is currently under investigation by Congress for perjury and perhaps other misdeeds) and reduced the "penalties" to Boeing to the laughable (if it weren't so wrong) one analogized above.

Once you have formed such a legal department, you are almost done in setting up your corrupt enterprise.

9. Corrupting government officials is not enough. Employees at your company and others who know about your illegal acts will be tempted to write their Representatives and Senators from their state, hoping they will bring you to justice by acting in the public interest, and not your corrupt company's interests in continuing your corruption. This may especially be the case if the live in a state with Democratic Congressional representatives. They may contact those Democratic Congressional Reps with the idea that a politician from the Democratic party would be more likely to oppose a large corrupt corporation like yours than a Republican would, as Repuiblicans generally support business rights over individual rights, and vice versa for the Democrats. Your corporation, however, must prove them wrong and prevent both Democratic and Republican parties from acting to stop your obvious corruption, no matter how many mere individuals contact them reporting your fraud. First of all, you must make any politician fear taking you on in the private or public arena, lest you donate heavily to their opponent's campaign in the next election. And, if the remain docile and sufficiently protect your interests, no matter how corrupt your company is, reward them well with campaign donations. Politicians must also keep in mind the voting of your employees. The more employees you have that will be negatively affected if a politician acts to expose and end your corruption, the less likely they will be to do so. Once you have neutered the potential threats from politicians exposing your fraud reported to them by emminently naive and ethical people by the above methods and others you may think of (having your lobbyists cozy up to them, etc.), you are ready for the next step in protecting your corrupt corporation from any form of justice for its actions.