FCPAméricas Blog

Archive for Gifts and Entertainment category:

FCPA Myths and Misconceptions, Debunked (Part 2: Enforcement)

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 […]

Author: Matteson Ellis

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No World Cup Tickets for Brazilian Federal Officials

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. […]

Author: Guest Author

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The Ten Most Important FCPA Internal Controls (Part 2: Other Processes)

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 […]

Author: Matteson Ellis

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What FCPA Enforcement is Thinking in 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). […]

Author: Matteson Ellis

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How Aggressive Is Your FCPA Gifts and Hospitality Policy in Mexico?

Gifts and hospitality present some of the thorniest issues for companies and business people subject to the FCPA and operating in Latin America. The FCPA does not prohibit providing gifts or hospitality to foreign officials. But the history of enforcement highlights that these practices are high risk and should be conducted with great care and […]

Author: Matteson Ellis

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