FCPAméricas Blog
Considering Reputational Risks in Brazil: A Growing Spotlight
12.08.2011
Guest Blog Post – Today FCPAméricas features author Gavin Parrish, a Practice Leader for Compliance and Fraud at Control Risks. He was previously an attorney in New York and São Paulo. Mr. Parrish can be reached at gavin.parrish@control-risks.com.
In previous posts, Matt has eloquently summarized some of the key operating and compliance challenges in Brazil, here and here. He has graciously invited me to share some additional thoughts on the reputational challenges that surface for our clients operating in Brazil.
Within the community of Brazilian lawyers involved in international transactions, the disclosure l... Read more
Assessing the Assessments: Using the TI Corruption Perceptions Index and other corruption risk metrics
12.06.2011
Guest Blog Post – Today FCPAméricas features author Juanita Riaño, an Integrity Officer at the Inter-American Development Bank and former Manager of the program “Global Tools to Measure Corruption” in the Transparency International-Secretariat. The opinions expressed in this blog post are entirely those of the author and do not reflect the position of the Inter American Development Bank.
Matt Ellis posted here last week that “enforcement officials and ‘best practice’ descriptions stress that adequate anti-corruption compliance programs [should be] based in sound corruption risk assessments.”
This is easier said than done. The truth is, there is no silver bullet to assess corruption risks. Measuring corruption is tricky because corruption is clandestine in nature: how can we expect to accurately assess the magnitude of a transaction that takes place under the table, in a brown envelope, or through a series of bank transfers around the globe?
The good news is that there has been tremendous progress in the development of integrity risk indicators. In ... Read more
Going Beyond the TI Index: New tools for assessing integrity risks
12.01.2011
Enforcement officials and “best practice” descriptions stress that adequate anti-corruption compliance programs are based in sound corruption risk assessments. Howard Sklar recently provided an in-depth look at how risk assessments can be used for maximum effect. The question remains, however: how should compliance officers assess the integrity risks presented by particular countries or industries?
Historically, companies have looked to their own experience and, frequently, to Transparency International’s Corruption Perceptions Index (the TI Index) to help identify country risk. The 2011 version of the TI Index was just launched today.
These are good first steps, but leave much to be desired. Fortunately, compliance officers have a growing number of metrics to consider when conducting such risk assessments.
The Mintz Group’s “Where the Bribes Are” Map
The James Mintz Group recently launched an online tool, the “Where the Bribes Are” Map, that measu... Read more
