A lot has been going on in Brazil in the anti-bribery field. There have been different developments that are noteworthy. This post highlights 5 relevant developments that took place in 2016. Other relevant developments will be summarized in the next post.
Car Wash continues to advance. The Operation Car Wash was initially launched in March 2014. In 2016 alone, 17 special operations were carried out by the Federal Prosecutors task force and 20 criminal charges were filed in connection with corruption, money laundering, conspiracy, and related crimes. In 2015, 15 special operations were carried out and 15 criminal charges were filed. In 2014, 8 special operations were carried out and 17 criminal charges were filled. In total, as of December 2016, the Car Wash resulte... Read more
The SEC 2016 Annual Report to Congress on the Dodd-Frank Whistleblower Program was published on November 15, 2016. This post highlights seven relevant aspects of the report.
Continuous increase in number of tips received by the SEC. The number of whistleblower tips the Commission receives annually continues to increase: 3,001 tips in the 2012 fiscal year, 3,238 tips in the 2013 fiscal year, 3,620 tips in the 2014 fiscal year, 3,923 tips in the 2015 fiscal year and 4,218 tips in fiscal year 2016. From fiscal year 2012, the first year for which we have full-year data, to fiscal year 2016, the number of whistleblower tips has grown more than 40 percent. Since August 2011, when the SEC’s O... Read more
A new book published recently in the United States is an excellent tool for FCPA compliance practitioners doing work in Latin America. The book, entitled The FCPA in Latin America: Common Corruption Risks and Effective Compliance Strategies for the Region, was written by Matt Ellis, who has extensive experience in international anti-corruption compliance and enforcement, with particular focus on Latin America (his full CV is available here), where he lived and worked.
With 214 pages divided into 8 chapters, the book covers numerous areas of FCPA compliance in Latin America and is must-read for anyone ha... Read more