FCPAméricas Blog
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FCPA Contract Provisions for Latin American Third Parties: The obligation to actively report certain information
10.11.2013
Recent FCPA enforcement actions have required companies to include compliance clauses in agreements entered into with third parties. This includes, among other things, representations related to compliance with anti-corruption laws, rights to conduct audits, and rights to terminate the agreement for any breach of anti-corruption laws and representations. A previous post discussed the difficulties faced […]
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FCPA Contract Provisions for Latin American Third Parties: Avoiding pitfalls of audit rights clauses
10.09.2013
FCPA enforcement actions in the recent past, as well as the FCPA Guidance, highlight the importance of including audit rights, and exercising those rights, in written contracts with third-party contractors. This post provides suggestions for avoiding pitfalls when establishing such rights in Latin America. A second post in this series highlights examples of information that […]
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“Every Dollar Has a Name”: Avoiding sham contracts in Latin America
5.17.2013
Personal finance guru and motivational speaker Dave Ramsey is known to say that “every dollar has a name” when advising audiences on how best to manage their money. This maxim holds true for companies seeking to comply with the FCPA as well. By implementing controls that help ensure that each company dollar is assigned a […]
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Who Is An FCPA Whistleblower?
12.20.2012
What type of person is an FCPA whistleblower? Is it someone just out to get rich? Is it a person constantly scheming to uncover wrongdoing where they work, to catch their employer in a bad act? Is it always a disgruntled worker who feels betrayed? Now that the Dodd-Frank whistleblower provisions have been in place […]
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What FCPA Enforcement is Thinking in 2012
11.19.2012
A year ago, FCPAméricas provided an overview of FCPA enforcement officials’ thinking at the time based on their comments at the 2011 National Conference on the U.S. Foreign Corrupt Practice Act, hosted by American Conference Institute (ACI). Last week, ACI held its 2012 national conference. Once again, FCPA enforcement officials shared their current thinking. Here […]