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1989.
Became Vice President - Legal Affairs, Sterling International Group, with executive responsibility for all legal matters abroad and extraterritorial U.S. legal compliance. Supervised staff attorneys in New York, London, Hamburg; coordinating with domestic legal staff and Kodak attorneys.

Personally advised on, negotiated Sterlings divestiture of its pharmaceutical manufacturing interests in Peru, responding to terrorist (sindero luminoso) threats at a time of grave local uncertainty