FCPAméricas Blog
Archive for Third Parties category:
Multi-Party Conspiracies in Central America: The Latest FCPA Case
8.24.2015
On August 12, 2015, the U.S. Department of Justice (“DOJ”) announced that Vicente Eduardo Garcia, a former executive of the software and technology solutions company SAP International, pled guilty to criminal charges of conspiracy to violate the U.S. Foreign Corrupt Practices Act (“FCPA”). Mr. Garcia also consented to a cease-and-desist order by the U.S. Securities and […]
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How CCOs Can Use the OECD Foreign Bribery Report
1.09.2015
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 […]
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The Tangible and Intangible Drivers of FCPA Risk in Venezuela Today
11.28.2014
Hugo Chavez came to power in Venezuela in 1999, riding a wave of dissatisfaction with the corrupt oligarchic elite that had governed the country for years. Despite his promise, corruption in Venezuela is still rampant, and might have gotten worse. Chavez’s successor, President Nicolas Maduro, just last week approved a set of strengthened anti-corruption laws […]
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FCPA Myths and Misconceptions, Debunked (Part 1: Compliance)
7.21.2014
When it comes to FCPA compliance and enforcement, myths and misconceptions abound. I’m not surprised to hear them from foreign business people with limited exposure to the FCPA. I am more concerned when I hear them in boardrooms, from the very executives most often exposed to individual liability under the law. These myths sometimes reflect […]
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The Ten Most Important FCPA Internal Controls (Part 2: Other Processes)
4.18.2014
Certain company processes might not constitute traditional notions of “internal controls,” but FCPA enforcement officials have taken the position that a wide range of activities is covered by the term. For example, in Orthofix, the SEC found that the company failed to maintain adequate internal controls when the company’s FCPA compliance policy and FCPA-related training […]