FCPAméricas Blog
Archive for Gifts and Entertainment category:
Healthcare Compliance Risks in Latin America
2.12.2015
In the last decade, there have been a number of FCPA enforcement actions in the healthcare sector. This post discusses some of the challenges faced by companies that operate in Latin America in this industry and ways to mitigate risks. While the challenges discussed are true regardless of the region, they are particularly relevant in […]
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FCPA Myths and Misconceptions, Debunked (Part 2: Enforcement)
7.24.2014
As noted in the previous post is this series, FCPA misconceptions are dangerous. For compliance programs to mitigate risks as intended, everyone in the organization needs to understand them consistently. Compliance officers need to be alert for common myths or misunderstandings related to what the FCPA requires. Part 1 of this series describes common misconceptions […]
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No World Cup Tickets for Brazilian Federal Officials
6.05.2014
This guest post is from Thiago Jabor Pinheiro, a Senior Associate at Mattos Muriel Kestener Advogados (MMK) in São Paulo, Brazil. Just days before the kickoff of the FIFA World Cup 2014, federal authorities in Brazil have issued regulations to prohibit Federal Executive Branch public officials from accepting invitations to World Cup games and events. […]
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The Ten Most Important FCPA Internal Controls (Part 2: Other Processes)
4.18.2014
Certain company processes might not constitute traditional notions of “internal controls,” but FCPA enforcement officials have taken the position that a wide range of activities is covered by the term. For example, in Orthofix, the SEC found that the company failed to maintain adequate internal controls when the company’s FCPA compliance policy and FCPA-related training […]
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What FCPA Enforcement is Thinking in 2013
12.06.2013
What is the current thinking of FCPA enforcement officials at the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC)? At ACI’s 30th International Conference on the FCPA this year, two top officials provided insights (they clarified that their statements reflected their own views and not the views of their respective agencies). […]