FCPAméricas Blog

Boom Times in Brazil, Part 2 (Managing corruption risk in a high-opportunity / high-risk environment)

Author: Matteson Ellis

This blog post is the second of a four-part series. Part 1 outlines corruption issues to look out for when operating in Brazil’s high-opportunity / high-risk environment. Part 2 (below) gives guidance to companies that are expanding operations into Brazil on ways to manage the country’s unique risk. Part 3 gives guidance (in Portuguese) to Brazilian companies expanding internationally on the basic prohibitions and jurisdictional elements of the FCPA. Part 4 discusses developments in Brazil that may signal a sea change in corruption reform.

Brazil presents unique corruption risks to companies making investments there, some of which are discussed in Part I... Read more

The World Bank Harmonizes Global Anti-Corruption Compliance Standards

Author: Matteson Ellis

Yesterday I attended a roundtable discussion at The World Bank (the Bank) about the Bank’s sanctions and anti-corruption efforts. The discussion included several high-level Bank staff who, together, are developing and implementing policies to prevent, detect, and respond to fraud and corruption in Bank-financed global development projects.

This is important work. In FY 2011 alone, the Bank has committed over $57 billion in credits, loans, grants, and guarantees, and it has a fiduciary responsibility to ensure that these funds are used for their intended purpose.

Though I have spent several years conducting fraud and corruption investigations for the Bank’s integrity unit (the Integrity Vice Presidency), it was not until yesterday that I first learned about the notable advancements the Bank has recently made on the private sector compliance side of the effort.

Pursuant to Section 9.03 of the new sanctions procedures, the Bank... Read more

Boom Times in Brazil, Part 1 (Five corruption issues to look out for in a high-opportunity / high-risk environment)

Author: Matteson Ellis

This blog post is the first of a four-part series. Part 1 (below) outlines corruption issues to look out for when operating in Brazil’s high-opportunity / high-risk environment. Part 2 gives guidance to companies that are expanding operations into Brazil on ways to manage the country’s unique risk. Part 3 gives guidance (in Portuguese) to Brazilian companies expanding internationally on the basic prohibitions and jurisdictional elements of the FCPA. Part 4 discusses developments in Brazil that may signal a sea change in corruption reform.

Brazilians are taking to the streets. Fed-up citizens are marching in the city squares of Rio de Janeiro with 594 brooms held-high, demanding a corruption clean-up, wit... Read more


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