FCPAméricas Blog

A New Focus in the Car Wash Probe

Author: Guest Author

This guest post is from Victoria Arcos and Fernanda Martins, anti-corruption lawyers at KLA Koury Lopes Advogados in Brazil. 

Brazilian anti-corruption efforts have a new focus – money laundering by banks. These are new targets and are directly connected to the illicit activity and vast corruption schemes that have been under investigation for the past years.

For example, on May 8, 2019,  arrest warrants were issued for 3 executives of Banco Paulista S.A... Read more

The FBI Speaks to Latin America about Corruption

Author: Matteson Ellis

In May 2019, leaders of the FBI’s anti-corruption efforts in Latin America addressed an audience of compliance professionals at the LEC Brazil International Compliance Congress in Sao Paulo. Special Agent Rick Simpson, who heads the FBI’s new dedicated international anti-corruption squad in Miami, and David Brassanini, who serves as the FBI’s Legal Attaché in Brazil, spoke about the FBI’s efforts in Latin America. This was a unique opportunity to hear directly from the FBI about its work and priorities in the region. The agents made the following general points:

Prioritizing Latin America. The FBI’s new dedicated anti-corruption squad in Miami reflects its k... Read more

How DOJ’s Updated Compliance Guidance is Relevant to Latin America

Author: Matteson Ellis

On April 30, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) issued updated guidance on the “Evaluation of Corporate Compliance Programs” (Updated Evaluation Guidance) intended to “assist prosecutors in making informed decisions as to whether, and to what extent, [a] corporation’s compliance program was effective at the time of the offense, and is effective at the time of a charging decision or resolution, for purposes of determining the appropriate (1) form of any resolution or prosecution; (2) monetary penalty, if any; and (3) compliance obligations contained in any corporate criminal resolution (e.g., monitorship or reporting obligations).”

Miller & Chevalier’s alert about the Updated Evaluation Guidance i... Read more


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