FCPAméricas Blog
Brazil’s “Car Wash” by the Numbers
12.18.2015
This 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 Federal Prosecutor’s Office (“MPF”) is one of the authorities in charge of enforcing the set of Brazilian laws combatting corruption. The MPF, along with the Federal Police and the Brazilian Judiciary, has played a key role in investigating, prosecuting and judging cases related to individuals and companies allegedly involved in a massive kickback scheme with the giant Brazilian state owned company Petroleo Brasileiro S.A. (“Petrobras”),... Read more
DOJ’s New Compliance Consultant: Real Versus Paper Compliance Programs
12.09.2015
This guest post is authored by Ben Gao and Alice Hsieh, associates at Miller & Chevalier Chartered.
At the November 2015 ACI International Conference on the FCPA, Hui Chen, the new “compliance expert” at DOJ’s Fraud Section, outlined her still “evolving” thinking on what separates a “real” compliance program from a “paper-based” one. This is of particular interest given Chen’s expected role in helping DOJ prosecutors and compliance monitors to evaluate companies’ compliance programs and remediation efforts.
Chen is a former prosecutor and compliance executive at three companies that each face distinct compliance challenges—Standard Chartered, Pfizer, and Microsoft. The DOJ hired her in early Nov... Read more
What FCPA Enforcement is Thinking in 2015
12.01.2015
Once 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
