FCPAméricas Blog
Archive for FCPA Guidance category:
Aiding, Abetting, Conspiracy … Non-U.S. Companies and Individuals … and the FCPA
1.04.2013
Non-U.S. companies and individuals should take note. Their actions do not have to occur in the territory of the United States for FCPA enforcement officials to assert jurisdiction over them. They do not even have to pay the bribes themselves to violate U.S. law. This is because the principles of aiding, abetting, and conspiracy under […]
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Eli Lilly’s Distributor in Brazil: The Non-Obvious FCPA Risk
12.31.2012
A common misconception about the FCPA is that distributors do not create corruption risk for companies. After all, distributors take title to goods. What they do with those goods is their business, not the producer’s. Eli Lilly’s recent $29.4 million FCPA settlement with the SEC dispels this myth. Actually, enforcement officials have been sending the […]
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The Most Important Features of the FCPA Guidance … for Latin America
12.14.2012
There are several reasons to read the recently published FCPA Guidance. FCPAméricas has described some of them, including its level of detail, hypothetical scenarios, and declinations. The current climate of enhanced enforcement is another obvious reason to do so. But some sections may be particularly interesting for Latin American audiences. Consider the following: 1. Context: The […]
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The Five Things I Love About the FCPA Guidance
12.11.2012
In the last few weeks, since the DOJ and SEC issued their FCPA Guidance, there has been much guidance written on the guidance. This new source covers much ground, and there is certainly a lot to say. Here are my five favorite things: 1. The Guidance compiles previously dispersed information. A common theme heard from […]