Part of the old "SEC Consent Decrees" issued in the late 70s took issue
with the records management practices of some of the firms that were
allegedly involved with "bribing" foreign officials.  

As I recall, one of the companies involved was a company known as Gulf
Oil.  It may be a bit ironic, but the International Comptroller who was
accuse of shredding many of the documents that the SEC sought to review,
was later charged with the responsibility of ensuring that Gulf met the
requirements of the Consent Decree, and was the "father" of the Gulf Oil
Records Management program of the 1980s.

Douglas P. Allen, CRM, CDIA+

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