McKinsey unit will pay $123M to settle claims it bribed South African officials
179 points
20 days ago
| 21 comments
| cnbc.com
| HN
languagehacker
20 days ago
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"McKinsey is a very different firm today than when these matters first took place"

No they are most certainly not. Corruption is in McKinsey's DNA. Outside of the specific harms that McKinsey has caused across the country and across the world, management consulting groups in general have been utilized to sidestep legal protections against corporations within a shared industry colluding against each other. Companies like McKinsey, Bain, Accenture, etc., have been instrumental in the rapid increase of executive compensation, flat comp for workers compared to inflation, intentionally unsafe practices and corner-cutting to save money, and just generally creating as many negative externalities as possible in the name of feeding the beast that Milton Friedman created with his rhetoric about the primacy of the shareholder.

A good read on this topic is "When McKinsey Comes to Town" by Forsyth and Bogdanich. There's a whole chapter dedicated to the South African bribery scandal. Sagar was not just a bad apple -- the company itself is the rot.

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chasd00
20 days ago
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Ah McKinsey, my favorite story was from my sister who worked there some years ago. McKinsey worked on strategy for the Obama and McCain campaigns at the same time! Heh talk about heads I win tails you lose. I guess an Obama win was what was best for McKinsey.
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cafard
20 days ago
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Abraham Lincoln brought back from the dead couldn't have won as a Republican in 2008 with the economy the way it was.
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vundercind
20 days ago
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Yuuuup. They launder both corporate espionage and collusion as “best practices” (where’d they learn those? Your company! And your competitors!)
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moshegramovsky
20 days ago
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Am I correct in remembering that they had some kind of involvement in the Purdue Pharmaceutical debacle? It seems like you are exactly right: McKinsey is not really a good company.
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mateus1
20 days ago
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They weren’t just involved. They were the brains behind some evil moves such as giving bonuses per opioid OD rates and bribing the best pill pushing doctors with bribes disguised as speaker fees.
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autoexec
20 days ago
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Did anyone at McKinsey & Co ever see a day in jail for it? Last I heard they didn't even have a conviction for anything, just settlements in which they agreed to a fine while they still insisted that they didn't do anything illegal.
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maeil
20 days ago
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No, hence we're now seeing cases like Brian Thompson's where citizens rightly take law enforcement into their own hands because the actual judiciary has been completely captured by the wealthy class.
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whatshisface
20 days ago
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Before we go too far down this road, post revolutionary France had the terror and produced a dictator that swept over Europe.
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bobs_salsa
20 days ago
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That’s a great point, and if that comes to be, that burden shall lay with the rich.

This should all serve as a warning to the wealthy on what will happen if they continue distancing themselves from accountability. It’s a zero sum game.

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maeil
20 days ago
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We're hundreds of miles off from going too far down this road. This is taking one step on a road that spans the globe.

It's about as relevant to bring this up now as it would have been to do so when people celebrated the death of Bin Laden, and I'm sure you didn't at the time. The latter even had an arguably better reason behind his acts that wasn't solely personal greed.

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fakedang
20 days ago
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A dictator, sure, but also a breath of fresh air from the previous regime that went on a mass-murdering spree.
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moshegramovsky
20 days ago
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100% hard agree.
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smt88
20 days ago
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It takes a lot to go beyond the corporate veil and hold individuals criminally liable. I think prosecutors rarely try unless it's a slam dunk.
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moshegramovsky
20 days ago
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I think it's more a case of "where there's a will, there's a way".
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soraminazuki
20 days ago
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I still can’t wrap my head around the fact that causing hundreds of thousands of deaths for profit doesn’t result in a swift conviction.
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datavirtue
20 days ago
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They are great at what they do.
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alexashka
20 days ago
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This.

More broadly, anyone that claims you can improve anything by sending randoms who read some books to companies and 'consult' there is selling you a fantasy.

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StableAlkyne
20 days ago
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There is some value in that they can ignore whatever dumb red tape exists at your company.

Also politically harder for middle managers to just ignore what the expensive consultants are suggesting

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psunavy03
20 days ago
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I once watched a webinar on YouTube by Dave Snowden, who invented Cynefin and was an IBM VP. I think his words were something like "I hired those guys from time to time, not because I had any intention of doing what they recommended, but because it got the board and C-Suite off my back long enough for me to frame the problem in my head and decide what I was going to do."
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alexashka
20 days ago
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Middle managers who read some books and proceed to 'manage' are selling you a fantasy.

You can't fix one fantasy with another fantasy.

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asdff
20 days ago
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Part of that is the side effect that the companies themselves are not giving their own employees time to actually pause from the slog in the trenches for a second and you know, read the book themselves. Instead book readers are brought in to consult on operations.
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highcountess
20 days ago
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They’re also an organization in which sexual predation is normal.
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awanderingmind
20 days ago
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Thank you for this, I agree.
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jjkaczor
20 days ago
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It isn't just them - all of the "big 4" do the same things - "KTMJ" has had dozens of scandals over the years...
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jncfhnb
20 days ago
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McKinsey is not a part of the big 4. And it’s KPMG
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Incipient
20 days ago
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I think they meant it as a acronym potentially? But the "big 4" are typically to refer to the accounting firms.

"big 3" are for management consulting? Bain, Boston, and mckinsey? Or does deloitte fit in there? Anyway neither here nor there.

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jjkaczor
14 days ago
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I meant it as a joke - it is a reference to the financial/accounting firm from the movie "The Batman"... bad enough it drove one of their auditors crazy ...
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awanderingmind
20 days ago
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As a South African, this is good news (it would have been nice if the payment was higher and more people at McKinsey were held accountable). Unfortunately we are unlikely to see accountability locally for whoever actually paid this bribe. The background is that this was part of the program of State Capture enabled by our former president (Jacob Zuma) and a very dubious family from India: https://en.wikipedia.org/wiki/Gupta_family. Our country was basically sold to the highest bidder - people speak of 'ten lost years'.
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DAGdug
20 days ago
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Wonder if Rajat Gupta, the former CEO of McKinsey who was incarcerated for sharing insider information, and the corrupt Gupta family, were connected in any way (they’re from the same inbred trading caste in India, a country that is sadly notoriously corrupt).
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fakedang
20 days ago
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Barring the insider trading case (where Rajat Gupta was largely an smaller accomplice to most of Rajaratnam's scheme), Rajat's rags to riches story is actually extremely inspiring. Perhaps he did not benefit from having good mentors - his mentor-professor at IIT Delhi being slimey Subramanian Swamy.

https://en.m.wikipedia.org/wiki/Subramanian_Swamy

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hilux
20 days ago
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AFAIK, they are not. Gupta is a very common name in India, and Rajat Gupta is from West Bengal.
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WangComputers
20 days ago
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It's impossible to do business in Africa without bribing people, all these laws do is put Western companies at a tremendous disadvantage compared to Chinese ones.
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passwordoops
20 days ago
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In my first real job about a decade ago, I asked the APAC/China rep why the prices were 30-40% higher... "The hookers and bribes tax. Hookers and bribes"
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akira2501
20 days ago
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> impossible to do business in Africa without bribing people

Why?

> all these laws do is put Western companies at a tremendous disadvantage

While attempting to address a serious problem. You could say this of any law.

> compared to Chinese ones.

Not a standard I care about or am willing to be held hostage to. Moral sacrifice to capture international business is pretty gross. Probably why it wasn't even hard to pass the law.

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ip26
20 days ago
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Why?

The explanation I've heard before is that when you need anything from a thoroughly corrupt government, as simple as a building permit or a visa for a foreign employee involved in a project, officials will simply not process your request without a bribe. They believe it is owed. End of story.

I don't like the explanation in the slightest. But I do see how it might shut down opportunity if you can't overpower the obstacles, and aren't willing to bribe.

The utility of US laws against bribing foreign officials is to break down the expectation by those officials of a bribe. But, from a game theory point of view, if China is willing to bribe, this becomes much less effective.

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unix_fan
20 days ago
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The same happens in Latin America as well. If you want to get through the layers of bureaucracy without being stuck for years in a process, you have to pay up. And it has to be a well-connected government official. That’s mostly the reason I don’t bother with anything entrepreneurship related here.
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highcountess
20 days ago
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Because there is no mechanism in basically all of Africa that would put some kind of limit on it. No strong governmental institutions, no moral framework, no religious framework. And to the contrary, the African continent is largely antithetical to western/European moral, ethical, and philosophical limitations.

People just assume Africans are the same as Europeans and Asians, etc. because they’ve had it hammered into their minds all their lives, but reality is that we are all quite different and that’s good in some ways and bad in others, but it’s different.

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abdulhaq
20 days ago
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Err totally wrong the entire north Africa has strong religious frameworks, and take Egypt as an example of a powerful government. Plenty of other places too.
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blackhawkC17
20 days ago
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Powerful government doesn’t imply strong institutions that uphold rule of law.

It’s usually the opposite…powerful governments rule with an iron fist but are internally marred by corruption and incompetence.

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abdulhaq
20 days ago
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I totally agree
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highcountess
20 days ago
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I knew I should specify sub-Saharan Africa, because there’s always that Reddit tier knowing and willful idiot contrarian that just can’t help themselves from just being opposite for sake of being opposite, due to a severe mental derangement that compels them to be that way.

We are not talking about North Africa here, we are talking about South Africa and South Africa like places, which would mean sub-Saharan Africa, not Egypt or Algeria or Tunisia. You lack refinement and do not contribute anything useful, and may want to reflect on why you have that contrarian compulsion. No one is talking about North Africa. All the intelligent people here know we are talking about Africa in the context of South Africa. You clearly lack fundamental skills to distinguish such things.

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weard_beard
20 days ago
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Adding: https://www.hup.harvard.edu/books/9780674299344

and: https://www.hup.harvard.edu/books/9780674979796

to my christmas list. I don't think the law or war are appropriate tools for establishing international morality, but maybe the right ones are somewhere in these.

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chasd00
20 days ago
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You can’t put a house over your head and food in your kid’s plate with morals.
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taskforcegemini
19 days ago
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I hope you will change your mind before you have kids of your own
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stonogo
19 days ago
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Sounds like a skill issue. People do it every day.
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axiolite
20 days ago
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US oil companies like ExxonMobile have survived on the international market just fine, despite the laws preventing them handing out bribes for the past several decades.

There are several examples of bribes being publicized and the guilty company losing out on big contracts as a result (e.g. from ECHELON spying).

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alborzb
20 days ago
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>> US oil companies like ExxonMobile

Is that the same ExxonMobile that was caught in a bribery corruption scandal in Liberia in Africa? [1]

Or perhaps you're talking about the same ExxonMobile that was caught bribing government officials in Kazakhstan in Asia? [2]

[1] https://www.business-humanrights.org/en/latest-news/full-rep...

[2] https://www.forbes.com/2003/04/23/cz_df_0423xom.html

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buckle8017
20 days ago
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Yeah they've survived by paying bribes.
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jamesfinlayson
20 days ago
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Yeah, I have a friend who worked in South-East Asia for a while - he said that his company paid "agents" whose job was specifically to pay the bribes on behalf of his company so that they themselves wouldn't get in trouble for paying the bribes.
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Beijinger
20 days ago
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AFAIK Ursula von der Leyen was minister of defense, she funneled gov consulting contract to McKinsey without an obligatory bidding process. Even some public employees were shocked by her behaviors. Worse, her son works for McKinsey.

In the end, who cares?

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passwordoops
20 days ago
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> In the end, who cares?

Certainly not the lawmakers

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sharpshadow
20 days ago
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Amazing the punishment is a bribe itself.
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some_random
20 days ago
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Do you genuinely believe that fines are the same as bribes?
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simpaticoder
20 days ago
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I never really thought about it, but yes, a fine without an admission of guilt is precisely a bribe. Consider the trade: you pay X dollars and in return they bury whatever evidence they have against you and you don't go to jail. Doesn't that describe a bribe to a cop or a judge or a prosecutor? As a corrallary I find it interesting that the media reports fines not as a fraction of net worth, but rather as an absolute amount. Clearly this serves the interest of both briber (who wants to be seen as punished more than it is) and the bribee (who wants the revenue, no matter how little it harms the briber).
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which
20 days ago
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When a decently sized percentage of it goes to "independent monitors" almost entirely run by ex-DOJ revolving door types, yeah. See https://www.forbes.com/global/2010/0607/companies-payoffs-wa...

And some think that FCPA enforcement and huge fines targeted at European companies like BNP Paribas motivated the creation of the EU tech extortion apparatus.

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some_random
20 days ago
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If you're going to argue that then it's not a bribe it's extortion which is very much a different thing.
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diffeomorphism
20 days ago
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The fines are more public. But low fines are otherwise pretty indistinguishable from "here is some money for you to look elsewhere".

As explained in other threads, McKinsey made almost the same amount of profit (adjusted for inflation) as the fine. So the message is:

- the effective fine (profit minus fine) is approximately 0, if you get caught.

- if you don't get caught, you get a profit of 120M.

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therobot24
20 days ago
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payment isn't bad, just need to make sure everyone gets their cut
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curtis3389
20 days ago
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Remember the name McKinsey. They are an evil organization that does bad things to good people. Anyone from McKinsey is to be regarded with suspicion at the very least.
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hilux
20 days ago
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I'm no McKinsey fan, but it's naïve to think that they are worse (or different) than other multinationals, particularly firms providing consulting or legal or other advisory services.
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brailsafe
20 days ago
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Surely we have to have some people lurking here that currently or used to be at McKinsey, I guess it wouldn't be surprising why they wouldn't chime in, but many have the same feelings about every other sus company many of us work for.
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bttrpll
20 days ago
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Everyone I worked with that had affiliation to McKinsey owned projects that ended up costing the company tens to hundreds of millions of dollars. They were better at office politics, however their actual skill was rubbish. Everyone paid for it, except them of course. In fact, after record layoffs guess who is still managed to keep their position? The McKinsey dudes. Crazy.
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jncfhnb
20 days ago
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I work there. It’s just a very decentralized place. What you do is driven by a tiny branch of the widest, flattest org you’ve ever seen. They’ve added some governance as to what partners can just sign up to do themselves. But it’s all firewalled internally. Idk what people in the next room over are doing to avoid creating conflicts of interest.

I would say a lot of people here are not grounded, but in more of an anxious way than an evil profit minded kind of way (which may sound mythical but I’ve seen it blatantly in other company cultures)

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antisthenes
20 days ago
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> not grounded, but in more of an anxious way than an evil profit minded kind of way

What do you mean by "anxious way" ?

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jncfhnb
20 days ago
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There’s simply a lot of anxious people with a lot of imposter syndrome. Half of the company encourages it. Half of the company discourages it.
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blackhawkC17
20 days ago
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Of course, the company of concern is Eskom, the underperforming state electricity monopoly whose incompetence has dragged the South African economy down.
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Aeolun
20 days ago
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McKinsey pays a bribe to settle claims it bribed in the past.

Very convincing.

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some_random
20 days ago
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A fine levied by a sovereign nation is different from under the table bribes to government officials.
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smegger001
20 days ago
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depends was the fine enough to make their action nonprofitable? if a fine is less than the profit from the action then its a cost of doing business
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some_random
20 days ago
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You can click on the article and read how much money the DOJ says McKinsey made from this bribe, and if you don't want to you can just take my word that it made this action unprofitable.
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lesuorac
20 days ago
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I'm not sure that's correct.

Plenty of companies do actions (like Uber) where they lose money for market share. So, penalizing McKinsey by making them forfeit profit isn't as big a punishment as it may seem.

It's a bit akin to if you were to steal a car, sell it, pay yourself a fee for that action and then have to return any money beyond that fee to the owner of the car. It's clearly a net gain for you still.

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FactKnower69
20 days ago
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apply your critical thinking skills before posting. $85M in 2014 dollars is $113M in 2024 dollars, and something tells me McKinsey didn't just leave the money sitting in a high yield savings account all this time
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some_random
20 days ago
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Oh so still less than the $123M fine? As for what they did with the money, I get the point that they could have reinvested it and made additional profit but I find it way too speculative to be worth discussion especially when the $85M number doesn't appear to be the marginal value of the bribe and is possibly inflated already.
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swifthesitation
20 days ago
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When the settlement cost is just the price of doing business... you know they made many times more than the fine.
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paulddraper
20 days ago
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You think they made more than $123M profit from this??

HN numbers are wild.

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echoangle
20 days ago
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That’s not strictly necessary for the claim. You have to factor in the odds of getting caught. If you do this and only get caught 10% of the time, you can make slightly less than 1/10 of the fine per case and still make money.
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paulddraper
20 days ago
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Fair.

Speeding isn't worth a $100 fine.

But if you only get caught 1/100 times you speed...

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Scoundreller
20 days ago
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I mean, speeding is a pre-crime
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RandallBrown
20 days ago
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The article says they made approximately 85 million from this. Since it happened 10 years ago, they may very well have made money on this deal.
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some_random
20 days ago
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If the DOJ estimate (which is always inflated, let's be real here) is $85M how could they have possibly made more than $123M on it? Unless you're talking about other hypothetical bribes that we don't know about.
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lesuorac
20 days ago
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Mixture of time value of money and interest/inflation.

You take that 85 Million and invest it (likely into growing a business unit but lets ignore that) and over 10 years it becomes greater than 85 million.

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brailsafe
20 days ago
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I might be splitting hairs here, but they say $85M in profit, not revenue, so presumably that would be margin on top of whatever they paid people to do nothing, and the fine is a portion of revenue that otherwise wouldn't have gone to them, of which $85M was profit.

Otherwise though, McKinsey was awarded $209M in federal gov contracts in Canada over 12 years, so the numbers themselves don't seem relatively outrageous in terms of what McKinsey makes news for.

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FactKnower69
20 days ago
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$85M in 2014 dollars is $113M in 2024 dollars, and something tells me McKinsey didn't just leave the money sitting in a high yield savings account all this time
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pluc
20 days ago
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It's a fee not a fine
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southernplaces7
20 days ago
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Not to defend your typical mendacious megacorp and its dishonest ways, but we should also focus attention on the other site of this equation, the governments operating in many countries.

They're usually pervasively, profoundly corrupt across many levels and will often actively encourage a culture of massive bribes by creating a regulatory environment so stifling that no other means of getting any project or major process done exists. Often they'll simply ignore their own laws to stop investment projects until someone coughs up money on an extra-official basis.

I'm not talking about these governments honestly and in good faith creating and applying regulations for the well-being of their own nation. I'm referring to laws so byzantine that they're in place more as a dragnet for bribes, which is applied only selectively on a pay as you go & stop when you don't basis.

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whatshisface
20 days ago
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Everyone knows that poor countries often have very corrupt governments, that's why there are laws in developed countries specifically written to address what's happened here that were written decades ago.
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southernplaces7
20 days ago
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Everyone knows it but it's impressive how often the media focus is made heavily on the businesses paying bribes while disregarding the government functionaries actively extorting those bribes, or at least happily accepting them and using mechanisms to keep them flowing.

Aside from these governments no longer doing that, what should private interests do, cease all investment and business in certain countries?

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sitkack
20 days ago
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Money shouldn't an allowed remedy for bribery.

I think community service by the c-suite, at $10/hr should suffice.

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ozgrakkurt
20 days ago
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Yeah or just couple years prison time seems fair
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FactKnower69
20 days ago
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federal minimum wage is $7.25 actually :(
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sitkack
20 days ago
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Perfect!
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londons_explore
20 days ago
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So why is this money paid to the US government?

Shouldn't it go to the south african government, since south africas taxpayers were the ones harmed?

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diffeomorphism
20 days ago
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Obvious answer: because this is the American lawsuit for breaking American laws and there is another separate South African one for breaking South African laws.
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blindriver
20 days ago
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No jail for anyone of importance as usual.
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Aloisius
20 days ago
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The sentence for the McKinsey partner who pled guilty hasn't been announced yet.
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mmooss
20 days ago
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How do we justify deregulation with situations like McKinsey, Boeing, FTX, Silicon Valley monopolies, etc.? It doesn't make sense to me that people who want competitive, safe markets and consumer protection don't use these endless examples.
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eviks
20 days ago
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Just from the side comment that's easy to justify: this monopoly would've been deregulated out of existence, so no bribes

> Of course, the company of concern is Eskom, the underperforming state electricity monopoly whose incompetence has dragged the South African economy down.

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betaby
20 days ago
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> How do we justify deregulation

What exactly you think was deregulated? In general and in this particular case.

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mmooss
20 days ago
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I mean the deregulation drive by the GOP, the next administration, and a many others.
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jongjong
20 days ago
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The bribe that keeps on bribin'...
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ulfw
20 days ago
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Cost of doing business for that company
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soraminazuki
20 days ago
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> How many uplifting McKinsey projects like "more snuggles at the puppet factory" or "make grandma live forever" would you need to hear about to effectively counterbalance "turbocharge the opioid epidemic," "help fuck up Rikers even more," and "make a Saudi Arabian snitch list"?

https://www.youtube.com/watch?v=AiOUojVd6xQ

Great video by John Oliver, as always.

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inemesitaffia
20 days ago
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Fascinating the money isn't going to the South African Government.

The harmed party

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yieldcrv
20 days ago
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Foreign Corrupt Practices Act is a Domestic Corrupt Practices Act
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moshegramovsky
20 days ago
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Bribery. So someone's going to jail?
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ozgrakkurt
20 days ago
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Not in this world. We might go to jail for stealing stuff though
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fallingknife
20 days ago
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Why is the US DOJ wasting time and money enforcing other countries laws for them? They broke the law in South Africa. Let South Africa handle it.
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vundercind
20 days ago
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Bribing foreign officials is illegal in the US. It prevents our country from becoming a haven and hot-spot for activity that harms the rule of law overseas and destabilizes foreign states, because we generally prefer that other countries not worry about that when setting their trade policies with us.
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delfinom
20 days ago
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I think it's more the CIA doesn't like competition, lmao
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vundercind
20 days ago
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This is kinda true, even with a generous take on the CIA: they don’t want rogue freebooters screwing with their plans—why, you might destabilize a democracy they weren’t planning to replace with a dictatorship!

But also the trading reputation of a country is kinda a common good that individuals can profit by tarnishing, which makes it a prime target for very-valid and probably-a-good-idea regulation of that sort.

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mr_toad
20 days ago
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So a state monopoly on soft power as well as hard power. Makes sense.
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vkou
20 days ago
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Because US companies bribing foreign officials is anti-competitive against US companies which don't.
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crazygringo
20 days ago
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Although you've got to balance that against the fact that US companies not bribing foreign officials will result in them losing business to foreign companies that are perfectly happy to bribe.

It's a good question to ask why Chinese companies are allowed to get business in Africa with bribery, and the US then doesn't allow its companies to compete on a level playing field with China.

Why should the US take a stance at all? Why not let South Africa deal with it? It's not harming the US, is it?

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vkou
20 days ago
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Foreign companies bribing foreign officials who operate in the US can also be sanctioned.

And if they don't operate in the US, it's not the US's business to police something a company that has no presence in it does.

It's very simple and consistent. Americans and American companies are subject to American laws. People and companies who are in America are also subject to American laws. If you are neither American nor in America, you are not.

Nearly every country in the world follows a very similar set of rules regarding jurisdiction.

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tzs
20 days ago
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That doesn't really address the question they asked, which is more about whether or not it should be illegal rather than whether or not it is consistent.

Your earlier comment justified it being illegal on the grounds that US companies bribing foreign governments is anti-competitive against other US companies that do not do so.

That's an economic justification, not a moral justification. But if we are considering it economically rather than morally then we do have to consider what happens in the case of a foreign country where bribery is common and there are companies other than US companies that are competing there.

In that case not allowing US companies to bribe does indeed level competition among US companies--they all lose equally to non-US companies. Is that actually a better economic outcome than allowing US companies to bribe (and thus compete with foreign companies) in countries where bribery is normal?

That's a complicated question.

It also might be a national security question if we continue heading into a new cold war kind of world. Is it better to have US companies operating in countries the US would like to influence even if those companies have to bribe to do so, or for US companies to stay out and cede influence to companies from countries on the others sides of that cold war?

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crazygringo
20 days ago
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> Nearly every country in the world follows a very similar set of rules regarding jurisdiction.

Actually, no. As a general principle, countries do not pass/enforce laws regarding potential criminal activity that their citizens commit against citizens of other countries while in those other countries.

To take an extreme example, if you murder a citizen of a foreign country while in that foreign country, your home country is generally not going to charge you with murder. If you come back home, they may extradite you to that foreign country at that country's request, since you broke the law there. But because you were in the foreign country and the victim was also foreign, it's not within domestic jurisdiction.

Laws against bribes paid abroad break this rule. And in 2022 it was found that only two countries in the world actively enforce bribery outside their borders -- the US and Switzerland [1].

So no, your assertion that this is how nearly every country in the world operates, is completely false. It's actually a gigantic exception.

(Things operate differently for military forces, war crimes, etc. But we're talking about regular civilian/corporate law here.)

[1] https://us.transparency.org/news/exporting-corruption-2022-s...

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OnlineGladiator
20 days ago
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Because they also broke the law in the US.
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paulddraper
20 days ago
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US law prohibits this behavior.

This is because the US wants other countries to confidently allow free trade or event privileged relations with it.

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ClumsyPilot
20 days ago
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In that case will USA honour guilty verdict of a foreign court and extradite bosses of McKenzey or you propose we just shelter criminals?
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fallingknife
20 days ago
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Yeah, sounds good to me
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mountainb
20 days ago
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bdangubic
20 days ago
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this comment would only makes sense if all US companies were strictly forbidden from doing any business of any kind outside the country's borders...
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