FCPAméricas Blog
Brazil Amends Leniency Agreement Rules under the BCCA
1.11.2016
By Esther Flesch, Bruno Maeda, Carlos Ayres, Erica Sarubbi, Leopoldo Pagotto, Camila Steinhoff, and Fernanda Bidlovsky*
On December 21, 2015, the Brazilian President amended Law No. 12,846/13 (“Brazil Clean Companies Act” or “BCCA”), which has been in force since January 2014 and was regulated by Decree No. 8,420/2015 in March 2015 (see further details about the regulation here). The Provisional Measure attenuates the sanctions and helps correct certain legal uncertainties.
Importan... Read more
New Corruption Risk Data for Mexico
12.31.2015
Lots of eyes are on Mexico right now, given the country’s efforts to develop a new National Anti-Corruption System, the opening up of its energy sector to foreign investment, and the reality of corruption risk that persists for business there, making attention to anti-corruption compliance of continued importance. It is fitting that two reputable actors in Mexico – PwC and FTI Consulting – have recently published new and helpful data related to the prevalence of corruption risk in the country.
The following data can help companies when developing business and compliance strategies on the ground. It can be used by compliance personnel when training employees in the country. It can help educate glo... Read more
Travel to Cuba: OFAC Encourages Reluctant Banks to Allow US Persons to Access Their Accounts
12.22.2015
The 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.
Almost a year ago, when the Administration began relaxing the Cuba embargo, one of the big questions was whether and how financial institutions would adapt to the new era. Without financing, it would be hard for any policy designed to increase travel to Cuba – as this new Cuba policy explicitly is – to succeed. Unfortunately, as many have reported, the financing has been slow t... Read more
