FCPAméricas Blog

Archive for Accounting Provisions category:

Views from FCPA Enforcement’s Latin American Specialists

More than any other FCPA enforcement office in the United States, Miami’s DOJ and SEC teams have developed a specialization in Latin America. They work cases like Alcatel, Stryker, Ralph Lauren, and Direct Access Partners, each with an important Latin American component. They benefit from language capabilities in Spanish, Portuguese, and French, allowing them to […]

Author: Matteson Ellis

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The Ten Most Important FCPA Internal Controls (Part 2: Other Processes)

Certain company processes might not constitute traditional notions of “internal controls,” but FCPA enforcement officials have taken the position that a wide range of activities is covered by the term. For example, in Orthofix, the SEC found that the company failed to maintain adequate internal controls when the company’s FCPA compliance policy and FCPA-related training […]

Author: Matteson Ellis

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The Ten Most Important FCPA Internal Controls (Part 1: Accounting Controls)

Under the FCPA, companies can be punished not only for the wrongful things they do, like paying bribes. They can also be punished for certain things they don’t do. In particular, the FCPA’s accounting provisions require companies to have internal controls in place. When companies do not have certain protections like appropriate  accounting systems and […]

Author: Matteson Ellis

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Key Aspects of the FCPA Accounting Provisions

The FCPA has two main provisions: (i) the anti-bribery provisions; and (ii) the books and records and internal control provisions. The second group is commonly referred to as the “accounting provisions.” (FCPAméricas provides a description of the basics of the FCPA in English, Spanish, and Portuguese.) When people talk about the FCPA, however, what usually […]

Author: Carlos Ayres

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“Every Dollar Has a Name”: Avoiding sham contracts in Latin America

Personal finance guru and motivational speaker Dave Ramsey is known to say that “every dollar has a name” when advising audiences on how best to manage their money. This maxim holds true for companies seeking to comply with the FCPA as well. By implementing controls that help ensure that each company dollar is assigned a […]

Author: Matteson Ellis

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