FCPAméricas Blog

Archive for Internal Reporting category:

Anti-Corruption Compliance Programs for SMEs: What Brazil Has to Say

Anti-corruption compliance programs are good for companies for several reasons. Among other things, they help prevent, detect and remediate wrongdoing; protect shareholders; add value to the image of the company; and can be an important mitigating factors in many countries when authorities determine which sanctions they will apply (if any) and the level of the […]

Author: Carlos Ayres

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Best Practices for Setting Up a Hotline

A hotline is an important element of a compliance program. The Resource Guide to the FCPA mentions that “an effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation”. Similarly, the […]

Author: Carlos Ayres

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FCPA Compliance Lessons from “The Informant” (Part 1: Wearing a wire for the FBI)

You might recognize Mark Whitacre from the movie The Informant. Matt Damon played his role as a whistleblower in a multi-billion dollar price fixing scheme. While Mr. Whitacre was ADM’s Divisional President of the BioProducts Division and Corporate Vice President of the company, he cooperated with the FBI, wearing a wire over the span of […]

Author: Matteson Ellis

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Considering Cultural Nuance in Your Latin American FCPA Hotline

Internal reporting mechanisms – like confidential hotlines – offer employees an anonymous way to report potential anti-corruption violations. Such mechanisms have become standard components of FCPA compliance programs. However, companies implementing such mechanisms need to consider a number of implementation issues, ranging from what technology should be used, how to educate employees on internal reporting, […]

Author: Matteson Ellis

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Who Is An FCPA Whistleblower?

What type of person is an FCPA whistleblower? Is it someone just out to get rich? Is it a person constantly scheming to uncover wrongdoing where they work, to catch their employer in a bad act? Is it always a disgruntled worker who feels betrayed? Now that the Dodd-Frank whistleblower provisions have been in place […]

Author: Matteson Ellis

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