FCPAméricas Blog
Road to a Corruption Overhaul (Brazil Revises its Foreign Bribery Bill)
3.23.2012
In January, FCPAméricas reported on how Brazil is currently considering an overhaul to its foreign bribery law (see Another BRIC in the Anti-Corruption Wall). The post described key features of the draft bill under consideration by the Brazilian Congress that would dramatically strengthen the law. The post noted how this development is happening at a time when Brazilian multinationals are going global and confronting foreign bribery risks of their own (see Embraer’s current corruption issues), and corruption at home is under the spotlight (the President’s administration has lost a seventh Minister to corruption allegations since the last post).
Now, a Special Committee created by the Brazilian Congress to analyze bill 6.826/2010 has recently presented a revised draft... Read more
FCPA @ SXSW (Six Considerations for Gifts, Travel, and Entertainment Compliance)
3.21.2012
Each year, Austin, Texas grows in importance. Last week, it was the center of the interactive, film, and music universes with its South by Southwest (SXSW) festival. Next fall, it will serve as the only U.S. city to host the Formula One. Events like these turn the city upside down. Roadside motels command $400 a night for tiny rooms. Whole sections of the city are shut down to car traffic. And people fly in from all around the world.
I attended my fifth SXSW last week. What struck me this year was the number of corporate events. IBM had its party at one of my favorite Mexican hotspots on the East Side. Businesses pitched new products right and left. Watching this, I could not help but think – these are the exact type of scenarios that can create thorny issues under the FCPA.
It is one thing for companies to host their best customers and potential clients at a festival like this. But what happens when they are public officials, especially foreign government officials? A company might want to bring a foreign client who happens to work for a state-owned entity to town to show off its new technology. It might want to use the festival to build goodwill or increase visibility in the eyes of that client. It might choose to give a... Read more
The Ideal Compliance Team
3.13.2012
I have previously written about The School for Ethics and Global Leadership (SEGL) in Washington, DC, a high school semester boarding program that I co-founded in 2009 whose mission is to prepare our country’s future leaders to be ethically strong and internationally aware.
I recently attended one of the school’s signature classroom lessons. The topic was leadership styles. It quickly became apparent that some of what high school juniors are learning at SEGL is directly relevant to what companies can learn about crafting effective internal FCPA/anti-corruption compliance teams.
Many have written about the various actors that should b... Read more
