Right, dt! In fact, no prosecutor could ever indict Michael on Cicci's testimony precisely because he never got a direct order. That's one of the reasons I think it's possible that Cicci actually may have consciously tried to help Michael by lying about never getting a direct order from him. At the end of GF, just as Tessio's about to be taken for a ride, Cicci says, "Tom, Sal, the boss says for you to go on ahead [to the meeting with Barzini]." Now, that could have been a made-up ruse to get Tessio into the car. But if Michael really did tell that to Cicci, it'd mean that he did get a direct order from Michael--in this case, an order directly relating to the murder of Tessio.