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Stryker Shines Light on Latin American FCPA Risks

Spanish and Portuguese translations of this article will be posted in the coming days. On Thursday, the SEC announced a settlement of FCPA violations with Stryker Corporation, making it the latest company penalized in connection with bribes paid in Latin America. This enforcement action highlights certain FCPA risks, and poses questions arising from the relatively […]

Author: Matthew Fowler

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How Latin American Countries Define “Public Official”

Under the FCPA, the meaning of “public official” is important to determining whether or not a specific payment is prohibited. This is because the anti-bribery provisions of the FCPA only apply to public bribery, that is, bribes paid to public officials of non-U.S. countries. The analysis is often linked to a determination of whether an […]

Author: Matteson Ellis

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Polo Pulls Out of Argentina … after Ralph Lauren Corp. Violates FCPA at Argentine Customs

Argentines certainly value their sense of style. Unfortunately, however, they just lost official retail access to the Polo brand. Ralph Lauren Corporation has decided to wind down its operations in the country. Yesterday’s FCPA settlement with the Ralph Lauren Corporation suggests that the company’s decision to pull out might be linked, at least in part, […]

Author: Matteson Ellis

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The Changing Role of the General Counsel … in Latin America?

A recent Harvard Business Review article entitled “The Rise of the General Counsel” discusses how the role, status, and importance of a company’s general counsel has changed in the United States. It calls this “one of the most important developments of the last 25 years.” The article discusses how the GC is now a core […]

Author: Matteson Ellis

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Other Notable FCPA Developments in Latin America in 2012

Earlier this week, FCPAméricas discussed Latin America’s Top FCPA Enforcement Activity in 2012. Today’s post offers three other notable FCPA developments in the region last year. These developments demonstrate how FCPA enforcement efforts are playing out there. Embraer Investigation Continues: The SEC’s investigation into potential corrupt payments by Brazil-based commercial airline manufacturer Embraer (the world’s […]

Author: Matteson Ellis

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