FCPAméricas Blog
Archive for Risk Assessments category:
What FCPA Enforcement is Thinking in 2012
11.19.2012
A year ago, FCPAméricas provided an overview of FCPA enforcement officials’ thinking at the time based on their comments at the 2011 National Conference on the U.S. Foreign Corrupt Practice Act, hosted by American Conference Institute (ACI). Last week, ACI held its 2012 national conference. Once again, FCPA enforcement officials shared their current thinking. Here […]
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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 […]
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Customs and Police Top Corruption Risks in Latin America (What this means for FCPA compliance)
7.06.2012
The 2012 Latin America Corruption Survey found that executives consider customs and police to present the highest levels of corruption risk throughout the region. The survey, organized by Miller & Chevalier, Matteson Ellis Law, and twelve law firms throughout the region, generated responses from more than 400 executives who work in Latin America for local, […]
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Four To-Dos before Seeking Outside FCPA Help
5.10.2012
General Counsel and Internal Compliance Officers get approached regularly by outside FCPA service providers. Lawyers, accountants, technology consultants, due diligence and investigation groups, and on-line trainers are all available to help. And we constantly remind you of this. Each day the number of options seems to grow, and there is good reason. With every prosecution, […]
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What Wal-Mart Should Have Done
5.04.2012
Since the Wal-Mart bribery story broke, several commentators have argued that companies like Wal-Mart, if they want to stay competitive in countries like Mexico, have no choice but to bribe. To them, the FCPA’s purpose is “strictly moral.” These arguments rest on notions of cultural relativism and the fact that the law disadvantages U.S. companies: […]