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More Companies Managing Third Party Corruption Risks in Latin America

This post was co-authored by Leah Moushey, a Law Clerk at Miller & Chevalier. The 2016 Latin America Corruption Survey, released by Miller & Chevalier and 13 partner law firms throughout the region, shows a notable increase in efforts by companies to mitigate risks that their third parties will pay bribes on their behalf. The […]

Author: Guest Author

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What FCPA Enforcement Is Thinking in 2014

Over the past three years, FCPAméricas has posted summaries of the views that lead FCPA enforcement officials provide at ACI’s International Conference on the FCPA (see posts from 2011, 2012, and 2013). This year, at the 2014 conference, Kara Brockmeyer (Chief of the FCPA Unit of the SEC’s Enforcement Division) and Patrick Stokes (Deputy Chief […]

Author: Matteson Ellis

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Ensuring Your “Upjohn” Does Not Sound Like “Miranda”

Attorneys conducting FCPA interviews generally start with a routine “Upjohn” warning – a sort of lawyerly throat-clearing. But to interviewees hearing this warning for the first time, it can be startling. In-house lawyers have reported to me that outside U.S. counsel are generally terrible at providing an Upjohn warning in a way that does not […]

Author: Matteson Ellis

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Perceptions in India: How one short news article speaks volumes about the FCPA

On August 31th, 2013, The Economic Times of India carried the headline: “Fear of anti-bribery laws slows down M&A deals in India.” This one short article, in the second-most widely read English-language business newspaper in the world, speaks volumes about perceptions and realities of the FCPA in the global economy. FCPA issues need not end […]

Author: Matteson Ellis

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M&A Transactions in Latin America: Practical tips for multinationals conducting anti-corruption due diligence (Part 3 — Sources to Review)

Multinationals should take into account certain local particularities when conducting M&A due diligence for anti-corruption compliance. Part I of this series describes how to manage resistance to due diligence from local companies. Part II discusses some key issues to look at during the diligence. This post discusses the following important sources of information in the […]

Author: Carlos Ayres

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