FCPAméricas Blog

Investigating Oneself: Why Latin American companies should conduct internal reviews

Author: Matteson Ellis

internal investigation

For companies managing FCPA compliance for years now, the importance of investigating allegations of internal wrongdoing might seem obvious. When an indication of an improper payment arises, it is better to get to the truth than to ignore it or to assume an innocent explanation that may not be supported by the facts. Indeed, this approach is an explicit expectation of FCPA enforcement officials. The FCPA Guide states, “[O]nce an allegation is made, companies should have in place an efficient, reliable, and properly funded process for investigating the allegation and documenting the company’s response, including any disciplinary or remediation measures tak... Read more

What U.S. Companies Can Now Do In Cuba

Author: Guest Author

CubaThe 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. Tim sat down with FCPAméricas to discuss the changing rules in the United States toward Cuba sanctions.

The press has reported widely on recent changes in Cuba sanctions policy. What can U.S. companies now do in Cuba?

The press surrounding President Obama’s announcement of changes to the Cuba policy has been a lot more dramatic than the changes themselves. That said, there have been substantial changes, which U.S. government agencies put into effect on January 15, 2015.

In terms of businesses, there have been three main cha... Read more

Ten FCPA Compliance Tips for Private Equity

Author: Matteson Ellis

Private Equity FCPAAs the drumbeat continues with observers predicting robust FCPA enforcement against private equity firms (see articles here and here), and on the eve of ACI’s 2nd Summit on FCPA, AML & OFAC Risks for Private Equity and Hedge Funds, it is a fitting time to overview some specific compliance strategies that private equity firms are employing to manage FCPA risks.

FCPAméricas previously summarized the ways in which private equity faces FCPA liability. This post offers ten tips for oversight of the compliance programs of their portfolio companies.

Risk m... Read more


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