FCPAméricas Blog
Archive for Whistleblowers category:
FCPA Compliance Lessons from “The Informant” (Part 1: Wearing a wire for the FBI)
8.21.2013
You might recognize Mark Whitacre from the movie The Informant. Matt Damon played his role as a whistleblower in a multi-billion dollar price fixing scheme. While Mr. Whitacre was ADM’s Divisional President of the BioProducts Division and Corporate Vice President of the company, he cooperated with the FBI, wearing a wire over the span of […]
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Brookfield: Notable Aspects of Corruption in Brazil
2.15.2013
Earlier this month, the Wall Street Journal reported that a prosecutor in Brazil has filed bribery charges against the Brazilian subsidiary of Canada-based Brookfield Asset Management. Brookfield is one of the world’s largest property investors. The civil charges allege that the subsidiary paid $640,000 in bribes to obtain construction permits around Sao Paulo. As part […]
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How FCPA Enforcement Officials Discover Violations
1.24.2013
People throughout Latin America often ask me how FCPA enforcement officials discover that a company has bribed a foreign official. It is a good question. Foreign bribery usually happens far away from the United States. Bribery by its very nature plays out in the darkness. Those committed to making improper payments are also committed to […]
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Tips on Tips (Four recommendations for responding to FCPA whistleblower information)
1.11.2013
At a time when there are significant incentives for FCPA whistleblowers to take their information directly to the government, it is essential that companies consider the ways they respond to whistleblower tips. Preliminary reports since the Dodd-Frank whistleblower provisions went into place indicate that whistleblowers are generally choosing to go to their companies first with […]
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Who Is An FCPA Whistleblower?
12.20.2012
What type of person is an FCPA whistleblower? Is it someone just out to get rich? Is it a person constantly scheming to uncover wrongdoing where they work, to catch their employer in a bad act? Is it always a disgruntled worker who feels betrayed? Now that the Dodd-Frank whistleblower provisions have been in place […]