FCPAméricas Blog
Anti-Bribery in Brazil: 2016 Year in Review (Part II)
3.03.2017
A lot has been going on in Brazil in the anti-bribery field. Some specific developments are particularly noteworthy. A previous post highlighted 5 relevant developments that took place in 2016. Four other relevant developments are summarized below.
Compliance as a requirement of public procurement. ENCCLA – Brazil’s National Strategy Against Corruption and Money Laundering – is a forum in the Brazilian government that brings together a broad range of ministries and agencies involved in the prevention and combat of money laundering and corruption. Members of ENNCLA include Federal Police, Federal Prosecutors, Office of the Comptroller General (CGU), and the Brazilian Securities and... Read more
The MPF’s Key Role in the Global Fight against Corruption
2.25.2017
This post was co-authored by Leah Moushey, an associate at Miller & Chevalier Chartered.
Since Operation Car Wash began in 2014, the Ministério Público Federal (“MPF”), Brazil’s federal prosecution service, has emerged as a leader in the global fight against corruption. In addition to its role as the principal entity prosecuting conduct related to Operation Car Wash—Brazil’s largest corruption investigation in history—the MPF has become a trusted and effective partner of U.S. enforcement agencies.
According to a chart published in Miller and Chevalier’s FCPA Winter Review 2017... Read more
The Language of Bribery in Latin America
1.30.2017
This post was co-authored by Leah Moushey, an associate at Miller & Chevalier.
To run an effective FCPA compliance program in Latin America, it is important to know the terms and phrases used locally to describe bribery. This helps companies identify corruption risks and respond with appropriate compliance strategies. Compliance trainings in the region are more effective when corruption risks can be explained using familiar terminology. Compliance audits and internal investigations can use local bribery terminology in electronic document searches to identify problematic issues.
As part of the 2016 Latin America Corruption Survey, released by Miller & Chevalier... Read more
