FCPAméricas Blog

Archive for Internal Investigations category:

The Attorney-Client Privilege in FCPA Internal Investigations

More and more Latin American companies are conducting FCPA internal investigations when faced with allegations that employees or business partners have engaged in corrupt acts, as discussed by FCPAméricas here. This includes taking appropriate steps, such as issuing document presevation “holds,” conducting internal investigation interviews, and considering voluntary disclosures to enforcement authorities. Latin American companies […]

Author: Matteson Ellis

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Investigating Oneself: Why Latin American companies should conduct internal reviews

For companies managing FCPA compliance for years now, the importance of investigating allegations of internal wrongdoing might seem obvious. When an indication of an improper payment arises, it is better to get to the truth than to ignore it or to assume an innocent explanation that may not be supported by the facts. Indeed, this […]

Author: Matteson Ellis

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Corporate Investigations in Latin America, According to Jim Mintz

FCPAméricas sat down recently with Jim Mintz, who runs the global investigations firm the Mintz Group, to get his thoughts on corporate investigations in Latin America. Describe your approach to corporate investigations. Lawyers and investigators begin each case knowing little or nothing about the subject company or issue.  It’s like standing outside a high wall. […]

Author: Matteson Ellis

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What FCPA Enforcement Is Thinking in 2014

Over the past three years, FCPAméricas has posted summaries of the views that lead FCPA enforcement officials provide at ACI’s International Conference on the FCPA (see posts from 2011, 2012, and 2013). This year, at the 2014 conference, Kara Brockmeyer (Chief of the FCPA Unit of the SEC’s Enforcement Division) and Patrick Stokes (Deputy Chief […]

Author: Matteson Ellis

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FCPA Voluntary Disclosure Considerations

Neither a company nor its directors or officers have an affirmative obligation under the FCPA to disclose knowledge of a violation. But enforcement officials stress that there are benefits to doing so, including more lenient treatment and credit when penalties are calculated. Recently, outgoing DOJ Fraud Section Chief Jeffrey Knox said in an interview with […]

Author: Matteson Ellis

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