FCPAméricas Blog

Will Brazil Slide Backwards in Its Anti-Corruption Efforts?

Author: Carlos Ayres

CGUBy Carlos Ayres and Bruno Maeda

The Office of the Comptroller General (CGU) is one of the essential bodies of the Brazilian government to fighting corruption. It is the body of the federal government responsible for auditing federal expenditures, promoting transparency, representing Brazil on international anti-corruption forums (i.e., OECD, OEA and UN), and sanctioning public employees involved in wrongdoing.  Moreover, under Brazil’s Clean Companies Act, the CGU has authority to investigate and apply administrative sanctions for the illegal acts committed against foreign public administrations. In the case of bribery of local officials at the Federal Executive branch level, the CGU has concurrent authority to initiate administrative proceedings against legal entities and to examine and correct proceedings handle... Read more

Anti-Corruption Compliance Programs for SMEs: What Brazil Has to Say

Author: Carlos Ayres

SMEAnti-corruption compliance programs are good for companies for several reasons. Among other things, they help prevent, detect and remediate wrongdoing; protect shareholders; add value to the image of the company; and can be an important mitigating factors in many countries when authorities determine which sanctions they will apply (if any) and the level of the sanction. More recently, they are becoming a competitive advantage for obtaining work (some companies are now only contracting with third parties, even small ones, that have compliance programs in place). They are also an advantage for attracting investment (in Brazil, under the Brazilian Clean Companies Act, parent, controlled or affiliated companies and consortium members can be jointly liable for illegal acts; as a result, compliance programs have become an important tool for investors ... Read more

Guatemala’s Turn against Corruption… with help from the CICIG

Author: Guest Author

GuatemalaThe is a guest post from Juan Carlos Tristan, an attorney at BLP Legal in Costa Rica.

Guatemala has been known for its history of oppression, extreme violence, and most recently political corruption.

Now, the Guatemalan people are reacting. The society has been indirectly motivated by the “International Commission Against Impunity in Guatemala” (“CICIG”) and is protesting against corruption, with notable results, as described in this post. The uncovering of certain sensitive corruption scandals over the last months has provoked a succession of extensive public protests and strikes in Guatemala.

Guatemala has not been involved in any significant FCPA enforcement actions so far (except for one plea agreement pursuant to the Shot Show cases); but the country has certainly suffer... Read more


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