FCPAméricas Blog

Archive for Procurement category:

Connecting the Dots: Latin America Examples of Common FCPA Anti-Bribery Violations

FCPAméricas has seen a spike in readership from Latin America suggesting that regional businesspeople and companies are increasingly seeking to understand the FCPA. Since we believe that having relatable examples is useful for new readers and for practitioners tasked with spreading the message to different audiences, this post seeks to ground discussions of common FCPA […]

Author: Matteson Ellis

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Corruption and Football, and Reforming FIFA

No region in the world might have more passion for football (soccer) than Latin America. And where there is passion, there is money. And where there is money, there is corruption. One example of corruption in football might be FIFA, the International Federation of Association Football. It is the federation of 209 national football organizations. […]

Author: Matteson Ellis

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The World Bank’s Anti-Corruption Coordination with National Authorities

How serious can The World Bank’s sanctions process really be? After all, the Bank’s investigators lack many of the powers that national authorities often take for granted. The powers to subpoena documents and search premises are just two examples. It is true that Bank investigators might have contractual audit rights. But what happens if the […]

Author: Matteson Ellis

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Cross-Debarment and Conflict of Laws: The next big challenge for World Bank and MDB sanctions

Today the World Bank hosts a colloquium on suspension and debarment joined by several multilateral development banks (MDBs). It is a fitting time to highlight the next big challenge facing their coordinated efforts to sanction the companies and individuals found to have committed corruption, fraud, and collusion in development projects – potential conflict of laws […]

Author: Matteson Ellis

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World Bank Sanctions: Formal Evidentiary Rules Don’t Apply

In the World Bank sanctions program, “[f]ormal rules of evidence shall not apply.” See Section 7.01 of the Sanctions Procedures. Indeed, the World Bank Sanctions Board has a high degree of discretion when considering evidence of corruption, fraud, and collusion. It has the authority to consider the “relevance, materiality, weight, and sufficiency” of “any kind […]

Author: Matteson Ellis

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