FCPAméricas Blog
Archive for Internal Investigations category:
FCPA Voluntary Disclosure Considerations
10.10.2014
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 […]
Comments | Print This Post | | Read more...
The FCPA “Elevator Pitch”: Selling Anti-Corruption Compliance to Latin American Executives
6.26.2014
In Latin America, informal conversations might be the most effective way to talk to executives about anti-corruption compliance. I have given a lot of presentations in boardrooms, executive suites, and at management conferences in the region. Those communications are useful, but I find that I make the most headway moving anti-corruption up a manager’s priority […]
Comments | Print This Post | | Read more...
Establishing Credibility with FCPA Enforcement Officials
5.20.2014
Alstom, the French energy and transportation firm, got off on the wrong foot in responding to an FCPA investigation by U.S. authorities, according to reports. The Assistant U.S. Attorney handling the matter described the company’s preliminary compliance with a grand jury subpoena as characterized by “fits and starts.” The company’s new lawyer, Patton Boggs’ Robert […]
Comments | Print This Post | | Read more...
Best Practices for FCPA Investigation Document Holds – Part II
3.25.2014
Companies should take affirmative steps to ensure relevant documents are preserved when an allegation of a potential FCPA violation is made. This often results in the issuance of a timely document hold memorandum to relevant employees. An earlier post describes the definition of the proper scope of the notice, who should receive it, routine documentation […]
Comments | Print This Post | | Read more...
Best Practices for FCPA Investigation Document Holds
3.20.2014
Once an allegation of a potential FCPA violation has been made, companies should investigate it and fully document their work. The preservation of relevant documents as early as possible is one of the most important steps to a credible investigation. The exact steps to be taken to preserve documents will depend on a number of […]