FCPAméricas Blog
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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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How Latin American Countries Define “Public Official”
10.17.2013
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 […]
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Results of the 2012 Latin America Corruption Survey
6.14.2012
Miller & Chevalier and Matteson Ellis Law joined with 12 Latin American law firms in a survey of companies spanning 14 countries in the Americas to gain an understanding of the extent of corruption throughout the region, the effects of corruption on companies operating in those countries, perceptions of the effectiveness of regional anti-corruption laws, […]
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Latin America is not a Country (Managing FCPA compliance when risks are diverse)
2.28.2012
I was recently asked to give a presentation on a webinar about common corruption risks in Latin America. My first reaction – impossible. As people in the region will sometimes tell you, “Latin America is not a country.” It is a massive region with more than half a billion people and 24 different nations represented. […]
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What FCPA Enforcement Is Thinking in 2011
11.14.2011
The annual National Conference on the U.S. Foreign Corrupt Practices Act (FCPA) in Washington, DC, hosted by American Conference Institute, is always a unique opportunity to hear from FCPA enforcement officials about what they are currently thinking. This year’s meeting did not disappoint. Held last week, it included noteworthy statements, some of which are provided […]