FCPAméricas Blog
Archive for Foreign Official/Instrumentality category:
“The Foreign Law Firm I Use has a Government Official as a Partner”
7.25.2012
A company recently asked me if the following scenario creates a potential FCPA issue: its Latin American operations wish to hire a law firm in Central America and one of the law firm’s partners concurrently serves in the President’s administration of that foreign country. Yes, this situation can certainly create an FCPA compliance issue. In […]
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A “Mexican FCPA”? Not Just Yet
7.20.2012
In an article published this week in Latin Lawyer (“Anti-bribery act brings Mexico up to OECD standards, say lawyers”), Mexican lawyers suggest that a new bribery law in Mexico is broad enough to satisfy OECD commitments. One lawyer even states, “It’s been called the Mexican Foreign Corrupt Practices Act.” The law is certainly a positive […]
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SEC: Local Language Essential to “Effective” FCPA Compliance
7.11.2012
What is the big lesson from yesterday’s $7.4 million SEC settlement with Lewisville, TX-based Orthofix, the latest FCPA action involving Latin America? The “FCPA Commentariat” will surely highlight how corruption risks are common in public procurement in countries like Mexico. FCPAméricas has written about that subject (The Anatomy of Corruption in Public Procurement) based on […]
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FCPA @ SXSW (Six Considerations for Gifts, Travel, and Entertainment Compliance)
3.21.2012
Each year, Austin, Texas grows in importance. Last week, it was the center of the interactive, film, and music universes with its South by Southwest (SXSW) festival. Next fall, it will serve as the only U.S. city to host the Formula One. Events like these turn the city upside down. Roadside motels command $400 a […]
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Latin America is not a Country (Managing FCPA compliance when risks are diverse)
2.28.2012
I was recently asked to give a presentation on a webinar about common corruption risks in Latin America. My first reaction – impossible. As people in the region will sometimes tell you, “Latin America is not a country.” It is a massive region with more than half a billion people and 24 different nations represented. […]