FCPAméricas Blog
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Whistleblowers: 2013 Year In Review
1.23.2014
Much has been written about FCPA enforcement trends in 2013. This post highlights five relevant developments of the last year related to SEC whistleblowers. Increase in the number of tips received by the SEC. The SEC 2013 Annual Report to Congress on the Dodd-Frank Whistleblower Program reports that “the number of whistleblower tips and complaints […]
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Latin America’s Top Anti-Corruption Stories of 2013
1.21.2014
[Editor’s Note: FCPAméricas previously highlighted 2013’s top FCPA stories here.] It is the time of year when FCPA practitioners reflect on the year just past and work to filter the signal from the noise. FCPAméricas covered many different Latin American anti-corruption stories over the last twelve months. In my estimation, the following stories are those most […]
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Latin America’s Top FCPA Stories of 2013
1.17.2014
In the world of FCPA enforcement, 2013 was a big year. Some have pointed out, “After getting off to a slow start, with no official corporate FCPA settlements announced in the first quarter, 2013 witnessed two of the top ten biggest settlements of all time.” Others cite “a nearly fourfold increase in the size of […]
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Corporations on the Hook in Latin America
12.12.2013
A common feature of Latin American legal systems is that they grant authorities a limited ability to sanction corporations. If you are a corporation, this may sound like good news. But as the OECD’s Director of Legal Affairs Nicola Bonucci said at an ABA event in Washington, D.C. recently, it creates a “big loophole” in […]
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No Honor Among Thieves: Another reason not to bribe
11.08.2013
In the SEC’s action against employees of Direct Access Partners for a bribery scheme involving Venezuela’s Banco de Desarrollo Economico y Social (BANDES), described here, the SEC proclaims that there is “No Honor Among Thieves.” One of the facts alleged in that case is that the U.S. participants falsified the amounts of their fraudulent fees […]