FCPAméricas Blog
Latin America’s Compliance “Circle of Trust”
6.19.2015
Successful compliance officers in Latin America regularly say that the most important lesson for effective compliance is to establish positive relationships with business units in a company. Patrick Henz, the Primetals Technologies Compliance Officer for the Americas, describes the need to establish a “circle of trust.” Weatherford’s Global Ethics & Compliance Director, Marco Padilla, similarly explains the relationship as one that must be built on confidence, where employees feel that they and their company will be better off if they disclose an issue than if they do not. Thus, he says, a compliance officer must be a “trusted business partner.” Compliance works best in Latin America when re... Read more
Best Practices for Conducting Risk Assessments
6.06.2015
A well-designed compliance program starts with a thorough risk assessment. The Resource Guide to the FCPA refers to risk assessments as a factor “fundamental to developing a strong compliance program”. Similarly, the Brazilian regulation on compliance programs sets forth that a risk assessment is one of the elements that will be taken into consideration when authorities evaluate a company’s compliance program. There are certain best practices that companies should consider when conducting risk assessments. This post highlights six.
Decide on assessment scope. A risk assessment can cover a wide range of risks depending on the nature of a company`s activity. From the outset, the professionals involved in conducting the risk assessment should determine which areas to address in the assessment ... Read more
The Attorney-Client Privilege in FCPA Internal Investigations
5.31.2015
More and more Latin American companies are conducting FCPA internal investigations when faced with allegations that employees or business partners have engaged in corrupt acts, as discussed by FCPAméricas here. This includes taking appropriate steps, such as issuing document presevation “holds... Read more
