FCPAméricas Blog

Archive for Risk Assessments category:

The Top Three Bribery Risks in Latin America

Latin America is a region of great diversity, from the food to the languages to the cultures and the people. This also means that the forms of bribery in the region can be extremely diverse too. Nonetheless, there are some common threats that FCPA practitioners in the region tend to confront time and time again. […]

Author: Matteson Ellis

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The Shadow of Fujimori: Common Corruption Risks in Peru

When Alberto Fujimori ruled Peru between 1990 and 2000, he brought security and stability to a country known for Shining Path terrorism, economic ruin, and runaway inflation. These accomplishments came with a downside – widespread corruption at the highest levels of government. President Fujimori now sits in prison serving a 25-year sentence for siphoning away […]

Author: Matteson Ellis

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More Latin American Data for your FCPA Compliance Program: Gauging levels of petty corruption

Companies operating in Latin America with robust anti-corruption compliance programs regularly welcome new data to help them better understand the landscapes in which they operate. Risk assessments are a fundamental component of FCPA compliance, as discussed by enforcement agencies in the FCPA Guidance and Attachment Cs to Deferred Prosecution Agreements. Quantitative measures help bolster the […]

Author: Matteson Ellis

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Eli Lilly’s Distributor in Brazil: The Non-Obvious FCPA Risk

A common misconception about the FCPA is that distributors do not create corruption risk for companies. After all, distributors take title to goods. What they do with those goods is their business, not the producer’s. Eli Lilly’s recent $29.4 million FCPA settlement with the SEC dispels this myth. Actually, enforcement officials have been sending the […]

Author: Matteson Ellis

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What a Top Brazilian Federal Judge Wants You to Know about Corruption There

Fausto De Sanctis is a federal appellate court judge in Brazil. His court is responsible for Sao Paulo and Mato Grosso do Sul states, which represent more than 50% of all federal cases in Brazil. Before that appointment, he served for years on a specialized court for money laundering and financial crimes, which included corruption […]

Author: Matteson Ellis

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