FCPAméricas Blog
Archive for Anti-Money Laundering category:
FCPA Meets AML (Part 3: Implications of prosecuting foreign officials in bribery cases)
11.12.2013
When it comes to bribery, it takes two to tango: the briber and the receiver. But the FCPA penalizes only the briber (or offerer, promiser, etc.). As described in earlier posts in this series (see Part 1 and Part 2), however, U.S. prosecutors are finding other ways – principally through application of money laundering statutes […]
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FCPA Meets AML (Part 2: How AML violations show up in FCPA cases)
11.05.2013
The DOJ is increasingly charging anti-money laundering (AML) violations in the context of FCPA violations. But AML laws are complex, and outside the scope of many FCPA compliance officers. How do AML problems arise in the FCPA context? Given this enforcement focus, and the significant penalties that can result from AML violations (as discussed in […]
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How Brazil Is Fighting Corruption
11.01.2013
The Brazilian government has been closing ranks against corruption using different tools. Some of them can serve as examples of possible measures to be taken by other countries in the region. This post describes some of the main measures that have been taken by the Brazilian government to fight corruption. Increased enforcement of anti-bribery laws. […]
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FCPA Meets AML (Part 1: What FCPA compliance officers should know about AML)
10.24.2013
The DOJ is increasingly charging violations of anti-money laundering (AML) laws in conjunction with FCPA violations. This trend appears to have started in 2007 when anti-money laundering violations were charged in the Alcatel, Willbros and Green matters. Since then, violations of AML laws have been charged against numerous individuals in connection with at least eight […]
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How the U.S. Government Criminally Charges a Latin American Public Official
5.28.2013
Last November, then Assistant Attorney General for the Criminal Division of the U.S. Department of Justice (DOJ), Lanny Breuer, told an audience at an FCPA conference: “If you are a foreign official, corrupt, and living in the United States, the U.S. Government will prosecute you.” This month the DOJ made public its criminal charges against […]