FCPAméricas Blog

Archive for Risk Assessments category:

New Pemex Corruption Risks

Over the years, companies providing goods and services to Petróleos Mexicanos (Pemex), Mexico’s state-owned oil & gas company, have faced numerous FCPA risks. Pemex is considered an “instrumentality” of a foreign government under the FCPA since it is controlled by the Mexican Government. As a result, its officials are considered “foreign officials” under the FCPA, […]

Author: Matteson Ellis

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New Corruption Risk Data for Mexico

Lots of eyes are on Mexico right now, given the country’s efforts to develop a new National Anti-Corruption System, the opening up of its energy sector to foreign investment, and the reality of corruption risk that persists for business there, making attention to anti-corruption compliance of continued importance. It is fitting that two reputable actors […]

Author: Matteson Ellis

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Best Practices for Conducting Risk Assessments

A well-designed compliance program starts with a thorough risk assessment. The Resource Guide to the FCPA refers to risk assessments as a factor “fundamental to developing a strong compliance program”. Similarly, the Brazilian regulation on compliance programs sets forth that a risk assessment is one of the elements that will be taken into consideration when […]

Author: Carlos Ayres

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Ten FCPA Compliance Tips for Private Equity

As the drumbeat continues with observers predicting robust FCPA enforcement against private equity firms (see articles here and here), and on the eve of ACI’s 2nd Summit on FCPA, AML & OFAC Risks for Private Equity and Hedge Funds, it is a fitting time to overview some specific compliance strategies that private equity firms are […]

Author: Matteson Ellis

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How CCOs Can Use the OECD Foreign Bribery Report

Last month, the OECD published its first Foreign Bribery Report, measuring transnational corruption based on data from the 427 foreign bribery cases that have been investigated, prosecuted, and concluded since the entry into force of the OECD Anti-Bribery Convention in 1999. In a panel discussion on December 10th, 2014, hosted by the OECD, International Bar […]

Author: Matteson Ellis

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