FCPAméricas Blog
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Cultural Considerations and the FCPA: Part 2 (Compliance)
12.22.2011
Do considerations of culture have a place in the FCPA? Yes and no – it depends on the context. Part 1 of this blog post discusses culture’s role in enforcement. Part 2 (below) discusses its role in compliance. Part II. Compliance. While cultural norms have no relevance in enforcement (see Part 1), they have an important […]
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More Wisdom from Tom Fox
12.13.2011
At last week’s World Compliance FCPA Summit 2011 in Houston, TX, U.S. FCPA compliance attorney Tom Fox offered important points of wisdom. “Document, Document, Document.” The bedrock components of an adequate FCPA compliance program are well known. Every deferred prosecution agreement since Panalpina has included an Attachment C outlining basic requirements (see, e.g., Attachment C […]
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Considering Reputational Risks in Brazil: A Growing Spotlight
12.08.2011
Guest Blog Post – Today FCPAméricas features author Gavin Parrish, a Practice Leader for Compliance and Fraud at Control Risks. He was previously an attorney in New York and São Paulo. Mr. Parrish can be reached at gavin.parrish@control-risks.com. In previous posts, Matt has eloquently summarized some of the key operating and compliance challenges in Brazil, […]