FCPAméricas Blog

Trump Administration Imposes Sanctions against Eight Members of the Venezuelan Supreme Court

Author: Guest Author

Venezuela Supreme CourtThe following guest post is from Timothy O’Toole, a Member of Miller & Chevalier, and Abby Cotterill, a Senior Associate of Miller & Chevalier. They focus on sanctions, export controls, and other international regulatory and compliance issues.

In March 2015, the Obama administration imposed economic sanctions against Venezuela arising out of what U.S. officials believed to be serious human rights violations and corruption by Venezuelan law enforcement officials. See more information at this post. Thoug... Read more

Costa Rica Adopts the OECD Anti-Bribery Convention

Author: Guest Author

OECD.CostaRicaThis a guest post from Juan Carlos Tristan, an attorney at BLP Legal in Costa Rica.

On May 10, 2017, the Costa Rican Congress approved the country’s adoption of the “Organization for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions” (the “OECD Anti-Bribery Convention”).

This decision undoubtedly represents a significant step towards the implementation of... Read more

Important Aspects of Mexico’s National Anti-Corruption System – Part 2

Author: Matteson Ellis

SNA2A prior post highlights five notable features of the new National Anti-Corruption System (SNA) in Mexico. This post discussed five more that could be particularly relevant to non-Mexican companies and individuals.

Individual Liability Bolstered. The SNA establishes the General Law of Administrative Liabilities and amends the Federal Criminal Code in ways that bolster individual liability for bribery and bribery-related offenses. Mexican and non-Mexican individuals will be liable for “serious administrative offenses,” such as bribery, collusion in public bid procedures, influence peddling, wrongful use of public resources, and wrongful recruitment of ex-public servants. The burden of proof for the administrative violation is relatively low – “beyond a reasonable doubt” – and the statute of limitations is long ... Read more


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