FCPAméricas Blog
Archive for Third Parties category:
Six FCPA Red Flags Missed by Key Energy in Mexico
10.11.2016
When U.S. enforcement officials review fact patterns related to FCPA violations, they do so with the benefit of 20/20 hindsight. At the time that the violation occurs, however, in the context of a fast-paced business environment, certain red flags might not stand out. Transactions in the moment might not seem as questionable as they do […]
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Miller & Chevalier Releases Results of 2016 Latin America Corruption Survey
8.08.2016
Despite more than three-quarters of businesspeople indicating that their country’s anti-corruption laws are ineffective, the 2016 Latin America Corruption Survey released by Miller & Chevalier Chartered and 13 partner firms shows marked signs of regionwide improvement in corporate compliance measures. In April and May 2016, Miller & Chevalier and 13 Latin American partner firms distributed […]
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New Pemex Corruption Risks
2.29.2016
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, […]
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New FCPA Risks in Mexico’s Historic Energy Reform
2.28.2016
In 2013, the Mexican Congress approved constitutional amendments to open oil & gas exploration and production to foreign investment, ending the monopoly of Petróleos Mexicanos (Pemex). In the second half of 2015, the Comisión Nacional de Hidrocarburos (CNH), the entity created by the Ministry of Energy to supervise the award of E&P blocks to private […]
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New Corruption Risk Data for Mexico
12.31.2015
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 […]