FCPAméricas Blog

Archive for Due Diligence category:

Third-Party Due Diligence—Not Just a One Time Thing

This post was authored by Leah Moushey, an Associate at Miller & Chevalier Chartered. It is no secret that a company can be held liable under the FCPA for misconduct carried out by third parties. Indeed, the majority of corporate resolutions involve the participation of agents, consultants, distributors, lawyers, accountants, or other third-party intermediaries. Under […]

Author: Guest Author

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New Book Published for FCPA Compliance Practitioners

A new book published recently in the United States is an excellent tool for FCPA compliance practitioners doing work in Latin America. The book, entitled The FCPA in Latin America: Common Corruption Risks and Effective Compliance Strategies for the Region, was written by Matt Ellis, who has extensive experience in international anti-corruption compliance and enforcement, […]

Author: Carlos Ayres

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More Companies Managing Third Party Corruption Risks in Latin America

This post was co-authored by Leah Moushey, a Law Clerk at Miller & Chevalier. The 2016 Latin America Corruption Survey, released by Miller & Chevalier and 13 partner law firms throughout the region, shows a notable increase in efforts by companies to mitigate risks that their third parties will pay bribes on their behalf. The […]

Author: Guest Author

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Six FCPA Red Flags Missed by Key Energy in Mexico

When U.S. enforcement officials review fact patterns related to FCPA violations, they do so with the benefit of 20/20 hindsight. At the time that the violation occurs, however, in the context of a fast-paced business environment, certain red flags might not stand out. Transactions in the moment might not seem as questionable as they do […]

Author: Matteson Ellis

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Anti-Corruption Compliance Programs for SMEs: What Brazil Has to Say

Anti-corruption compliance programs are good for companies for several reasons. Among other things, they help prevent, detect and remediate wrongdoing; protect shareholders; add value to the image of the company; and can be an important mitigating factors in many countries when authorities determine which sanctions they will apply (if any) and the level of the […]

Author: Carlos Ayres

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