FCPAméricas Blog

Archive for Third Parties category:

How DOJ’s Updated Compliance Guidance is Relevant to Latin America

On April 30, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) issued updated guidance on the “Evaluation of Corporate Compliance Programs” (Updated Evaluation Guidance) intended to “assist prosecutors in making informed decisions as to whether, and to what extent, [a] corporation’s compliance program was effective at the time of the offense, and […]

Author: Matteson Ellis

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Third-Party Due Diligence—Not Just a One Time Thing

This post was authored by Leah Moushey, an Associate at Miller & Chevalier Chartered. It is no secret that a company can be held liable under the FCPA for misconduct carried out by third parties. Indeed, the majority of corporate resolutions involve the participation of agents, consultants, distributors, lawyers, accountants, or other third-party intermediaries. Under […]

Author: Guest Author

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New Book Published for FCPA Compliance Practitioners

A new book published recently in the United States is an excellent tool for FCPA compliance practitioners doing work in Latin America. The book, entitled The FCPA in Latin America: Common Corruption Risks and Effective Compliance Strategies for the Region, was written by Matt Ellis, who has extensive experience in international anti-corruption compliance and enforcement, […]

Author: Carlos Ayres

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More Companies Managing Third Party Corruption Risks in Latin America

This post was co-authored by Leah Moushey, a Law Clerk at Miller & Chevalier. The 2016 Latin America Corruption Survey, released by Miller & Chevalier and 13 partner law firms throughout the region, shows a notable increase in efforts by companies to mitigate risks that their third parties will pay bribes on their behalf. The […]

Author: Guest Author

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Costa Rica Strengthens its International Bribery Laws

This guest post is by Juan Carlos Tristan, a lawyer at BLP law firm in Costa Rica. Costa Rica has intensified its regulatory policies regarding transnational bribery. On July 21st, the Costa Rican Congress approved the Reform Bill amending the “Transnational Bribery Criminal Offense”, codified in Article 55 of the Anti-Corruption and Illicit Enrichment Law. […]

Author: Guest Author

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