FCPAméricas Blog
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Latin America’s Most Common Reaction to the FCPA
7.24.2015
Over the years, I have learned to count on a common reaction when discussing FCPA compliance in Latin America – “Well, you have corruption in the United States too.” Latin Americans are surprised to hear that the FCPA’s anti-bribery provisions address only foreign bribery – the payment of bribes to non-U.S. government officials. They often […]
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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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Responding to Bribe Requests
5.28.2014
Unfortunately, companies in Latin America and elsewhere continue to face demands for bribes when conducting business. While many companies have implemented policies and procedures prohibiting bribery and communicated them to employees, oftentimes employees do not know what to do or say when confronted with a bribe request. This post highlights how companies can address this […]
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How Top-Level Management Shows FCPA Compliance Commitment
5.02.2014
One of the most important elements of an effective FCPA compliance program is top-level commitment, what might be called “tone from the top.” Those at the top of an organization are in the best position to foster a culture of compliance. As indicated in the FCPA Guidance, the DOJ and SEC “consider the commitment of […]
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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 […]