FCPAméricas Blog
Archive for Procurement category:
Anti-Bribery in Brazil: 2017 Developments
3.05.2018
Much has been happening in Brazil in the anti-bribery arena. Several developments have been noteworthy. This post highlights five that took place in 2017. Guideline on Leniency Agreements. On August 24, 2017, the 5th Chamber of Federal Prosecutors, the body of the Brazilian Federal Prosecution Service dedicated to supporting integration and coordination in the fight […]
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Six FCPA Red Flags Missed by Key Energy in Mexico
10.11.2016
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 […]
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New FCPA Risks in Mexico’s Historic Energy Reform
2.28.2016
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 […]
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An Emerging Anti-Corruption Culture in Colombia? One Recent Case Suggests So
1.14.2016
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 […]
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Multi-Party Conspiracies in Central America: The Latest FCPA Case
8.24.2015
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 […]