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Restitution for Bribe Victims: U.S. obstacles vs. international trends

Tom Waits sang, “the large print giveth, and the small print taketh away.” The same might be said for the notion of restitution for FCPA victims. As discussed in a previous post, U.S. law appears to obligate courts to order restitution for FCPA victims – at least in some cases – but restitution generally does […]

Author: Matthew Fowler

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The Unknowns of Brazil’s New Anti-Bribery Law (Part 1, What will enforcement look like?)

Brazil’s new Anti-Bribery Law, just signed into law this month, has already generated much attention. And with good reason. It makes highly innovative changes to Brazil’s laws, including the establishment of corporate liability for bribery offenses, a strict liability standard for administrative and other penalties, increased sanctions, and credit for self-disclosure, cooperation, and corporate compliance […]

Author: Matteson Ellis

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Perspectives on Corruption in Peru from the Attorney who Put Fujimori and Montesinos in Jail

Among his many accomplishments as a criminal lawyer and international human rights practitioner, Jose Carlos Ugaz Sánchez-Moreno might best be known for his work as the lead special state attorney responsible for putting former President Alberto Fujimori and former head of Peru’s Intelligence Service Vladimiro Montesinos in jail for corruption. Mr. Ugaz currently practices law […]

Author: Matteson Ellis

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More Latin American Data for your FCPA Compliance Program: Gauging levels of petty corruption

Companies operating in Latin America with robust anti-corruption compliance programs regularly welcome new data to help them better understand the landscapes in which they operate. Risk assessments are a fundamental component of FCPA compliance, as discussed by enforcement agencies in the FCPA Guidance and Attachment Cs to Deferred Prosecution Agreements. Quantitative measures help bolster the […]

Author: Matteson Ellis

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All Eyes on Colombia, and Generational Change

Last weekend’s Summit of the Americas put all eyes on Colombia and, in doing so, generational change. In the sixth such meeting of regional leaders, thirty-three Heads of State met in a country that, until recently, was known for war, drugs, and kidnappings. As President Obama stated: “[T]here was a time not so long ago […]

Author: Matteson Ellis

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