FCPAméricas Blog

The FBI Speaks to Latin America about Corruption

Author: Matteson Ellis

In May 2019, leaders of the FBI’s anti-corruption efforts in Latin America addressed an audience of compliance professionals at the LEC Brazil International Compliance Congress in Sao Paulo. Special Agent Rick Simpson, who heads the FBI’s new dedicated international anti-corruption squad in Miami, and David Brassanini, who serves as the FBI’s Legal Attaché in Brazil, spoke about the FBI’s efforts in Latin America. This was a unique opportunity to hear directly from the FBI about its work and priorities in the region. The agents made the following general points:

Prioritizing Latin America. The FBI’s new dedicated anti-corruption squad in Miami reflects its keen focus on the region. Agents are working on a significant number of cases involving Latin America, many with ties to the Miami area. The focused squad will allow the FBI to increase its caseload in the region, and more FCPA investigations involving Latin America should be expected. The agents cited Brazil, Mexico, and Colombia as three priority countries for the FBI’s investigative efforts.

Latin American companies and individuals under the microscope. When there is a U.S. nexus, the FBI will investigate an entire scheme, including any conspiracies involving non-U.S. entities and individuals. This means they investigate U.S. companies and individuals, global companies and their employees, and local companies and individuals as well.

More than just corruption. While the dedicated squad in Miami is focused on corruption, the FBI remains interested in various other forms of corporate misconduct as well. The agents cited kleptocracy, money-laundering, and anti-trust violations as examples.

Cultural fluency. The FBI’s Latin American teams include professionals who know the region, speak local languages, and are familiar with how business is done on the ground. Cultural nuance is conveyed to FBI agents in periodic trainings. Agents gain an understanding of local custom by spending significant amounts of time on the ground.

Close cooperation with Latin American countries. The FBI has strong relationships with investigative agencies throughout the region. The agents cited Colombia, Peru, Chile, and Mexico as examples, and emphasized Brazil, where cooperation was described as fluid, seamless, and transparent. Agents regularly attend regional conferences where they coordinate with their peer groups from other Latin America countries.

The opinions expressed in this post are those of the author in his or her individual capacity and do not necessarily represent the views of anyone else, including the entities with which the author is affiliated, the author`s employers, other contributors, FCPAméricas, or its advertisers. The information in the FCPAméricas blog is intended for public discussion and educational purposes only. It is not intended to provide legal advice to its readers and does not create an attorney-client relationship. It does not seek to describe or convey the quality of legal services. FCPAméricas encourages readers to seek qualified legal counsel regarding anti-corruption laws or any other legal issue. FCPAméricas gives permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author and to FCPAméricas LLC.

© 2019 FCPAméricas, LLC

Matteson Ellis

Post authored by Matteson Ellis, FCPAméricas Founder & Editor

Categories: Brazil, Enforcement, English, FCPA

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