FCPAméricas Blog
Archive for Audits category:
Third-Party Due Diligence—Not Just a One Time Thing
4.11.2018
This post was authored by Leah Moushey, an Associate at Miller & Chevalier Chartered. It is no secret that a company can be held liable under the FCPA for misconduct carried out by third parties. Indeed, the majority of corporate resolutions involve the participation of agents, consultants, distributors, lawyers, accountants, or other third-party intermediaries. Under […]
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The Language of Bribery in Latin America
1.30.2017
This post was co-authored by Leah Moushey, an associate at Miller & Chevalier. To run an effective FCPA compliance program in Latin America, it is important to know the terms and phrases used locally to describe bribery. This helps companies identify corruption risks and respond with appropriate compliance strategies. Compliance trainings in the region are […]
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More Companies Managing Third Party Corruption Risks in Latin America
11.03.2016
This post was co-authored by Leah Moushey, a Law Clerk at Miller & Chevalier. The 2016 Latin America Corruption Survey, released by Miller & Chevalier and 13 partner law firms throughout the region, shows a notable increase in efforts by companies to mitigate risks that their third parties will pay bribes on their behalf. The […]
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Book-Ending FCPA Compliance: The Importance of Risk Assessments and Monitoring
12.23.2014
Over the last four years, at ACI’s winter International Conference on the FCPA, enforcement officials have repeatedly placed special emphasis on two specific compliance areas: risk assessments and monitoring. To be sure, these officials have discussed many of the essential elements of an effective anti-corruption compliance program, including tone from the top, internal reporting mechanisms, […]
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FCPA Myths and Misconceptions, Debunked (Part 1: Compliance)
7.21.2014
When it comes to FCPA compliance and enforcement, myths and misconceptions abound. I’m not surprised to hear them from foreign business people with limited exposure to the FCPA. I am more concerned when I hear them in boardrooms, from the very executives most often exposed to individual liability under the law. These myths sometimes reflect […]