FCPAméricas Blog
Archive for Procurement category:
Behind the “Pantalla”: Common Corruption Risks in Mexico
8.15.2012
As William Finnegan wrote recently in an illuminating New Yorker article, “in Mexico, it is often impossible to know who is behind something.” This is an important reminder for FCPA compliance officers. It is often a challenge to know what is going on in your foreign operations. Due diligence, trainings, audits, and risk assessments are […]
Comments | 
Print This Post
| | Read more...
World Bank Sanctions: Theories of Liability for Corruption, Fraud, and Collusion
8.09.2012
In a previous post, FCPAméricas provided “big picture” guidance for lawyers who work on World Bank sanctions matters. In this post, we provide an overview of the theories of liability for corruption, fraud, and collusion that the Sanctions Board has applied in the first cases it has considered. These are the theories on which the […]
Comments | Print This Post
| | Read more...
World Bank Sanctions: Guidance for Practitioners
8.06.2012
The World Bank sanctions system has teeth. Just ask Oxford University Press, Alstom, KBR, and the more than eighty other companies and individuals debarred over the last year for violating the Bank’s Procurement Guidelines and Consultant Guidelines with corruption, fraud, or collusion. Or ask the numerous entities currently under investigation by the Bank’s Integrity Vice […]
Comments | Print This Post
| | Read more...
A “Mexican FCPA”? Not Just Yet
7.20.2012
In an article published this week in Latin Lawyer (“Anti-bribery act brings Mexico up to OECD standards, say lawyers”), Mexican lawyers suggest that a new bribery law in Mexico is broad enough to satisfy OECD commitments. One lawyer even states, “It’s been called the Mexican Foreign Corrupt Practices Act.” The law is certainly a positive […]
Comments | Print This Post
| | Read more...
SEC: Local Language Essential to “Effective” FCPA Compliance
7.11.2012
What is the big lesson from yesterday’s $7.4 million SEC settlement with Lewisville, TX-based Orthofix, the latest FCPA action involving Latin America? The “FCPA Commentariat” will surely highlight how corruption risks are common in public procurement in countries like Mexico. FCPAméricas has written about that subject (The Anatomy of Corruption in Public Procurement) based on […]