FCPAméricas Blog
Archive for Venezuela category:
Latin America’s Top FCPA Stories of 2013
1.17.2014
In the world of FCPA enforcement, 2013 was a big year. Some have pointed out, “After getting off to a slow start, with no official corporate FCPA settlements announced in the first quarter, 2013 witnessed two of the top ten biggest settlements of all time.” Others cite “a nearly fourfold increase in the size of […]
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No Honor Among Thieves: Another reason not to bribe
11.08.2013
In the SEC’s action against employees of Direct Access Partners for a bribery scheme involving Venezuela’s Banco de Desarrollo Economico y Social (BANDES), described here, the SEC proclaims that there is “No Honor Among Thieves.” One of the facts alleged in that case is that the U.S. participants falsified the amounts of their fraudulent fees […]
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How Latin American Countries Define “Public Official”
10.17.2013
Under the FCPA, the meaning of “public official” is important to determining whether or not a specific payment is prohibited. This is because the anti-bribery provisions of the FCPA only apply to public bribery, that is, bribes paid to public officials of non-U.S. countries. The analysis is often linked to a determination of whether an […]
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How the U.S. Government Criminally Charges a Latin American Public Official
5.28.2013
Last November, then Assistant Attorney General for the Criminal Division of the U.S. Department of Justice (DOJ), Lanny Breuer, told an audience at an FCPA conference: “If you are a foreign official, corrupt, and living in the United States, the U.S. Government will prosecute you.” This month the DOJ made public its criminal charges against […]
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Results of the 2012 Latin America Corruption Survey
6.14.2012
Miller & Chevalier and Matteson Ellis Law joined with 12 Latin American law firms in a survey of companies spanning 14 countries in the Americas to gain an understanding of the extent of corruption throughout the region, the effects of corruption on companies operating in those countries, perceptions of the effectiveness of regional anti-corruption laws, […]