FCPAméricas Blog
Archive for Internal Investigations category:
Ensuring Your “Upjohn” Does Not Sound Like “Miranda”
11.19.2013
Attorneys conducting FCPA interviews generally start with a routine “Upjohn” warning – a sort of lawyerly throat-clearing. But to interviewees hearing this warning for the first time, it can be startling. In-house lawyers have reported to me that outside U.S. counsel are generally terrible at providing an Upjohn warning in a way that does not […]
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Polo Pulls Out of Argentina … after Ralph Lauren Corp. Violates FCPA at Argentine Customs
4.23.2013
Argentines certainly value their sense of style. Unfortunately, however, they just lost official retail access to the Polo brand. Ralph Lauren Corporation has decided to wind down its operations in the country. Yesterday’s FCPA settlement with the Ralph Lauren Corporation suggests that the company’s decision to pull out might be linked, at least in part, […]
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Tips on Tips (Four recommendations for responding to FCPA whistleblower information)
1.11.2013
At a time when there are significant incentives for FCPA whistleblowers to take their information directly to the government, it is essential that companies consider the ways they respond to whistleblower tips. Preliminary reports since the Dodd-Frank whistleblower provisions went into place indicate that whistleblowers are generally choosing to go to their companies first with […]
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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 […]
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How Local Laws in Latin America Affect FCPA Compliance Programs
9.19.2012
Extending an anti-corruption compliance program to subsidiaries in Latin America might seem like a straightforward proposition. A U.S. company must simply export its program, right? But this is not necessarily the case. To make a program effective locally, companies must consider local laws too, as highlighted in a recent webinar presented by Latin American law […]