FCPAméricas Blog

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

Banco Do Brasil’s New York Branch Learns the Hard Way to Beware of the “Good Guy Exception List”

Author: Guest Author

BancodoBrasilThe following guest post is from Timothy O’Toole, a Member of Miller & Chevalier who focuses on sanctions, export controls, and other international regulatory and compliance issues.

Earlier this month, Banco Do Brasil’s (BDB) New York branch agreed to pay a $139,500 civil penalty arising out of what the U.S. Treasury’s Office of Foreign Assets Control (OFAC) labeled as BDB’s “apparent violations” of the Iranian Transactions and Sanctions Regulations (the Iran sanctions).  A careful review of what happened (or at least what the settlement suggests happened) can help other companies and financial institutions learn from BNB’s situation, especially when it comes to the handling of what is commonly referred to as the “good guy exception list.”

To understand where the “good guy exception list” fits into the U.S. sanctio... Read more

Merrill Brink Publishes English Translation of Brazil’s Integrity Program Guidelines

Author: Matteson Ellis

M-B_StackedEarlier this month, FCPAmericas described the guidelines that Brazil’ Office of the Comptroller General (CGU) issued clarifying the elements of compliance programs set forth in the Clean Companies Act.  Merrill Brink International has now published an English translation of the guidelines.  The English translation can be found here... Read more


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