FCPAméricas Blog
Archive for Internal Investigations category:
Best Practices for FCPA Investigations in Latin America
2.19.2014
Oftentimes, an FCPA investigation will require obtaining information that is entirely outside of the United States. Because of this, local considerations are important. This post highlights four practical steps that companies can take to maximize the efficiency of their FCPA investigation in Latin America and minimize collateral consequences. 1. Capture local sources of information. When […]
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Chronicle of a Bribe Foretold: ADM in Venezuela
2.13.2014
A gripping cautionary tale is hidden in the Statement of Facts attached to the Archer Daniels Midland (ADM) non-prosecution agreement (NPA). The NPA, which ADM signed with the DOJ last December, related in part to FCPA violations in Venezuela, as well as Ukraine. The total FCPA settlement amount was $54.3 million. In summarizing the underlying […]
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When to Use Outside Counsel for FCPA Investigations
2.12.2014
These days, more and more companies are developing internal resources to manage potential FCPA violations. They bring to bear triage committees, internal audit teams, investigation units, and in-house lawyers when running issues to ground. This trend makes sense. Companies in high-risk industries and countries frequently need to vet indications of foreign bribery. Using outside lawyers, […]
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Voluntary Disclosures, through the Eyes of FCPA Enforcement
12.10.2013
When James Cole, Deputy Attorney General of the United States, gave his keynote address at ACI’s 30th International Conference on the FCPA, he dedicated an inordinate amount of time to the issue of self-disclosures of FCPA violations. “We at the Department are committed to demonstrating the benefits to your working cooperatively with us,” he said. […]
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Adding It Up: Why FCPA Investigations Are So Expensive
11.27.2013
When considering FCPA liability, companies need to factor in not only the potential fines and penalties associated with a violation. They also need to consider the costs associated with a government investigation, costs that are often overlooked but can be considerable. FCPA investigation costs regularly climb into the millions of dollars. While Stryker paid just […]