Chapter 14 - My board investigates me
The Holt archive triggered an independent board investigation into old Rourke disclosures.
I recused from leading it.
I hated that.
Judith Sloan hired former federal prosecutor Aaron Feld and forensic accountants.
They reviewed:
East Haven payments.
Old compliance representations.
My signatures.
The 2018 civil settlement.
What management knew when.
Seraphina believed the archive could destroy me.
It did not.
It did something more uncomfortable.
It made me answer questions I had avoided for sixteen years.
“Did you know East Haven passed money to union intermediaries?”
“At the time, no direct knowledge.”
“Did you suspect the payments were not ordinary consulting?”
“Yes.”
“Why sign?”
“My father told me to.”
“Is that your answer?”
“No.”
Good.
“My answer is that I wanted not to know.”
There.
Willful blindness in ordinary language.
Whether that met a criminal standard was for counsel.
Morally, I knew.
I had used ambiguity the way my father used closed doors.
Keep the project moving.
Do not ask what peace costs.
The investigation found no evidence I personally directed bribes or knew specific recipients.
It did find that two old compliance questionnaires I signed used language broader than I should have accepted:
I had represented no knowledge of improper payments.
More accurate would have been:
No direct knowledge.
That distinction mattered.
The company voluntarily disclosed the newly located Holt records to the relevant federal compliance monitor? The old monitor ended. Better: to outside counsel and then regulators under existing reporting obligations.
No raid.
No overnight arrest.
Review.
May you like
Seraphina’s threat created real corporate pain.
That did not give her authority over Anouk.
