FCPAméricas Blog

Archive for FCPA Guidance category:

Corruption Risk and the 2016 Rio Olympics: Raising the Bar for Hospitality Compliance

This post is authored by Carlos Ayres, along with Senior Associate Geoff Martin and Associate Jean-Paul Theroux in Baker & McKenzie LLP’s Compliance, Investigations and Government Enforcement practice in Washington D.C. The Olympic Games open in Rio de Janeiro on August 5, 2016. The Games are seen as an opportunity for hosts to show themselves […]

Author: Guest Author

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FCPA Compliance Strategies for Extortion in Latin America

This post was co-authored by Maryna Kavaleuskaya, a Law Clerk at Miller & Chevalier. Extortion can be an unfortunate reality for those doing business in Latin America. Rural highway shakedowns and intimidation by military personnel can and does occur in places like Venezuela. Underpaid and corrupt local police in Mexico sometimes invent violations just to […]

Author: Matteson Ellis

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Multi-Party Conspiracies in Central America: The Latest FCPA Case

On August 12, 2015, the U.S. Department of Justice (“DOJ”) announced that Vicente Eduardo Garcia, a former executive of the software and technology solutions company SAP International, pled guilty to criminal charges of conspiracy to violate the U.S. Foreign Corrupt Practices Act (“FCPA”). Mr. Garcia also consented to a cease-and-desist order by the U.S. Securities and […]

Author: Matteson Ellis

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Best Practices for Conducting Risk Assessments

A well-designed compliance program starts with a thorough risk assessment. The Resource Guide to the FCPA refers to risk assessments as a factor “fundamental to developing a strong compliance program”. Similarly, the Brazilian regulation on compliance programs sets forth that a risk assessment is one of the elements that will be taken into consideration when […]

Author: Carlos Ayres

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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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