FCPAméricas Blog

What FCPA Enforcement is Thinking in 2015

Author: Matteson Ellis

DOJOnce again, top level FCPA enforcement officials from the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) provided an overview of current enforcement trends and priorities at this year’s ACI International Conference on the Foreign Corrupt Practices Act on November 17, 2015. The DOJ’s Assistant Attorney General for the Criminal Division, Leslie Caldwell, and Deputy Chief of the Fraud Section’s FCPA Unit, Patrick Stokes, and the SEC’s FCPA Unit Chief, Kara Brockmeyer, offered their thoughts. This is the fifth year in a row that FCPAméricas has summarized what FCPA enforcement officials are saying at ACI (see overviews from 2011, 2012, 2013... Read more

The Lack of Legal Certainty in BCCA Leniency Agreements

Author: Guest Author

UncertaintyThis guest post is from Eloy Rizzo, a senior attorney with the law firm KLA – Koury Lopes Advogados in São Paulo, Brazil. Mr. Rizzo focuses on anti-corruption and compliance issues, as well as on complex litigation. Mr. Rizzo currently interns at Miller & Chevalier’s anticorruption team in Washington, DC.

The Brazilian Clean Company Act (“BCCA”) came into effect on January 29, 2014 establishing the civil and administrative strict liability for legal entities for acts against the public administration, either foreign or Brazilian. Among the applicable penalties are monetary fines ranging from 0,1 to 20% of the legal entity’s gross revenues of the last fiscal year, the publication of the sentence and the prohibition to receive public incentives, subsidies, donations or ... Read more

6 Reasons to Have an Anti-Bribery Compliance Program

Author: Carlos Ayres

SixAn anti-bribery compliance program is a system of self-governance established by companies in order to prevent and detect bribery acts and remediate compliance failures. In a global marketplace, an effective anti-bribery compliance program is becoming a critical component of a company’s business model. There are various reasons for why a company should have such a program in place. This post highlights six.

Mandatory requirement. While in most jurisdictions companies are not obligated to have anti-bribery compliance programs, in certain jurisdictions they may be required to do so. In the UK, for example, companies can be liable for failure to prevent bribery. Local laws may require companies to have other sorts of compliance programs. In many jurisdictions, anti-money laundering laws, for example, obligate individuals and legal persons ... Read more


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