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The Language of Bribery in Latin America

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 […]

Author: Guest Author

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More Companies Managing Third Party Corruption Risks in Latin America

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 […]

Author: Guest Author

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Book-Ending FCPA Compliance: The Importance of Risk Assessments and Monitoring

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, […]

Author: Matteson Ellis

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FCPA Myths and Misconceptions, Debunked (Part 1: Compliance)

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 […]

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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