FCPAméricas Blog

Anti-Corruption Efforts in the Caribbean: Enforcement, Civil Society, and the Multilateral Development Banks

Author: Matteson Ellis

ABA Section of International Law croppedOn September 30, the American Bar Association, Section of International Law is presenting a panel discussion teleconference regarding Anti-Corruption efforts in the Caribbean. The panel will be moderated by Matthew Fowler – a regular contributor to FCPAmericas – and will feature prominent anti-corruption voices from the region.


Anti-Corruption Efforts in the Caribbean:

Enforcement, Civil Society, and the Multilateral Development Banks

Program 7 of the International Anti-Corruption Committee’s ‘Around the World’ Series

A non-CLE program proudly presented by

ABA Section of International Law

International Anti-Corruption Committee

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“Compliance Programs Required to Comply with BCCA”: The Fallacy of the Brazilian Clean Company Act

Author: Guest Author

HammerThis guest post was written by Alexandre Serpa, a compliance professional based in Sao Paulo, Brazil.

The act had barely been enacted and the headlines were everyone, stating “Companies start to implement Compliance Programs to comply with the new law …” The articles in newspapers, blogs, magazines and other media either stated explicitly or implied that the implementation of a compliance program was now ‘mandatory’ under the new law. Readers were given the impression compliance is a pre-requisite for fulfillment of the Law. And

Personally, I believe that this hype is not justified at this time. First, consider the following scenario:

You have a task: drive a nail into a wooden board.

The majority of us, if not all of us, immediately think that we “have to” get a hammer, because the hammer is essential for the task of driving the nail into the wooden board.

To the majority of us the hammer becomes more important than t...Read more

Revisiting U.K. Anti-Corruption Enforcement on the Third Anniversary of the Bribery Act

Author: Guest Author

UKBAThis guest post is from Geoff Martin, an Associate from Baker & McKenzie’s London office currently working with the firm’s Compliance & Investigations Group in Washington, DC.

U.K. Bribery Act came into force in July 2011. At that time, the Act was heralded as a key part of a new global wave of robust anti-corruption legislation with the promise of a marked increase in enforcement.

In the three years that have followed, there has neither been the volume nor the profile of Bribery Act enforcement that some had predicted. Indeed, there has yet to be a single corporate conviction under the Act. The cases that have been brought to-date all involve relatively small-scale domestic bribery by individuals. This is in contrast to the multi-million dollar instances of complex international corruption matters that continue to be the subject of U.S. FCPA enforcement.

There are a number of factors that may help to explain the re...Read more