FCPAméricas Blog
Whistleblowers: 2015 Year in Review
2.12.2016
The SEC 2015 Annual Report to Congress on the Dodd-Frank Whistleblower Program was published on November 16, 2015. This post highlights four 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, and 3,923 in the 2015 fiscal year. The number of tips related to FCPA issues also continues to rise. In total, 186 tips received in the 2015 fiscal year were related to alleged FCPA violations. In fiscal year 2012, 2013, a... Read more
Latin America’s Top Four Anti-Corruption Compliance Mistakes
1.27.2016
Attention to anti-corruption compliance has grown dramatically in Latin America in the last few years. The trend is fueled by continued robust enforcement of the FCPA against Latin American-based companies, the recognition of compliance programs as mitigating factors in local legal regimes, and the increased willingness of certain local governments to enforce their own anti-corruption laws. This has led to a rise in local compliance know-how in various parts of the region. Communities of attorneys, accountants, investigators, and other compliance professionals are forming quickly in markets like Brazil, Mexico, Argentina, and Colombia.
With this new attention to compliance, some common mistakes are also emerging. The following four were expresse... Read more
An Emerging Anti-Corruption Culture in Colombia? One Recent Case Suggests So
1.14.2016
The following guest post is from Luis Lizarralde, a Certified Fraud Examiner and Colombian attorney with experience in cross border transactions.
The recent prosecution in Colombia of Alvaro Cruz, the former Governor of the Department of Cundinamarca, tells us many different things about corruption in Colombia. It highlights the persistent corruption risks in the construction and engineering sectors in Colombia. It shows that government officials are positioned not only to receive bribes but to pay bribes too. It involves a failed effort by Cruz to manipulate the criminal justice system, with more bribes, after the corruption investigation began. Most importantly, it reflects recent changes in Colombian law that have made it easier for prosecutors to pursue ... Read more
