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Six FCPA Red Flags Missed by Key Energy in Mexico

When U.S. enforcement officials review fact patterns related to FCPA violations, they do so with the benefit of 20/20 hindsight. At the time that the violation occurs, however, in the context of a fast-paced business environment, certain red flags might not stand out. Transactions in the moment might not seem as questionable as they do […]

Author: Matteson Ellis

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New FCPA Risks in Mexico’s Historic Energy Reform

In 2013, the Mexican Congress approved constitutional amendments to open oil & gas exploration and production to foreign investment, ending the monopoly of Petróleos Mexicanos (Pemex). In the second half of 2015, the Comisión Nacional de Hidrocarburos (CNH), the entity created by the Ministry of Energy to supervise the award of E&P blocks to private […]

Author: Matteson Ellis

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An Emerging Anti-Corruption Culture in Colombia? One Recent Case Suggests So

The following guest post is from Luis Lizarralde, a Certified Fraud Examiner and Colombian attorney with experience in cross border transactions. The recent prosecution in Colombia of Alvaro Cruz, the former Governor of the Department of Cundinamarca, tells us many different things about corruption in Colombia. It highlights the persistent corruption risks in the construction […]

Author: Guest Author

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Multi-Party Conspiracies in Central America: The Latest FCPA Case

On August 12, 2015, the U.S. Department of Justice (“DOJ”) announced that Vicente Eduardo Garcia, a former executive of the software and technology solutions company SAP International, pled guilty to criminal charges of conspiracy to violate the U.S. Foreign Corrupt Practices Act (“FCPA”). Mr. Garcia also consented to a cease-and-desist order by the U.S. Securities and […]

Author: Matteson Ellis

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Brazilian Clean Companies Act: Three Practices to Prevent Fraud in Public Procurement

This guest post was written by Felipe Ferenzini, senior associate at Trench Rossi & Watanabe Advogados. The long-awaited Brazilian Clean Companies Act entered into force on January 29, 2014 and set forth strict rules to prevent the corruption that has been plaguing the country. As a result of Brazil`s change of attitude toward enforcement of […]

Author: Guest Author

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