FCPAméricas Blog

Archive for UK Bribery Act category:

Beyond the FCPA: Commercial Bribery, the Travel Act, and Compliance

Today’s guest post is from anti-corruption attorney Matthew Fowler who formerly worked as a compliance officer at a multinational defense company. When I was an in-house compliance officer, the issues that kept me up at night were not the ones covered by our compliance program. They were the unknown unknowns – the issues I feared […]

Author: Matthew Fowler

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The Government’s Response to the Proposed Affirmative FCPA Compliance Defense

At the recent ACI 2012 National Conference on the U.S. Foreign Corrupt Practices Act, the U.S. Government provided a direct response to the U.S. Chamber of Commerce’s affirmative compliance defense proposal. Over the last two years, since the Chamber issued its proposed amendments to the FCPA, the Chamber has advocated for “a defense that would […]

Author: Matteson Ellis

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What Private Equity Should Know about Recent SFO Developments

Recent developments at the UK’s Serious Fraud Office (SFO) should be on private equity’s radar. If institutional investors subject to UK jurisdiction fail to ensure that their portfolio companies have anti-corruption compliance programs in place, they risk having the proceeds from their investments seized when those proceeds flow from corrupt acts. This is the case […]

Author: Matteson Ellis

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Mitt Romney, Private Equity, and the FCPA

I admit it. Latin America is not my only passion. I am also a political junkie. Four years ago, I took a month’s leave from my Washington, DC law firm to trudge through the New Hampshire snow in support of my chosen candidate. I went door to door, sat in strangers’ living rooms, and stuck […]

Author: Matteson Ellis

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Third Party Red Flags and Latin America

Looking back at FCPA enforcement actions in 2011 that involved Latin America, all but one included risk created “indirectly” by third parties. And that one, Tyson Foods, involved payments to spouses of Mexican officials, a potentially odd twist on the concept of “third party risk.” The kind of third parties used in these cases included […]

Author: Matteson Ellis

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