FCPAméricas Blog

Book-Ending FCPA Compliance: The Importance of Risk Assessments and Monitoring

Author: Matteson Ellis

Over the last four years, at ACI’s winter International Conference on the FCPA, enforcement officials have repeatedly placed special emphasis on two specific compliance areas: risk assessments and monitoring.

To be sure, these officials have discussed many of the essential elements of an effective anti-corruption compliance program, including tone from the top, internal reporting mechanisms, trainings, and third party due diligence (FCPAméricas has posted summaries from 2011, 2012, 2013... Read more

Five Ways that Latin American Companies and Individuals Can Be Subject to FCPA Jurisdiction

Author: Matteson Ellis

5 bases for jurisdiction post imageThere is a lot of talk in Latin America these days about the FCPA. People throughout the region see investigation after investigation and settlement after settlement including companies and individuals from the region. They are asking more questions about the law, such as — How can Latin Americans be subject to a U.S. law? Here are five ways that U.S. authorities can assert jurisdiction over non-U.S. companies and individuals under the FCPA’s anti-bribery provisions:

Issuers (15 U.S.C. Sec. 78dd-1). The FCPA applies to Latin American companies that... Read more

What FCPA Enforcement Is Thinking in 2014

Author: Matteson Ellis

SECFCPAOver the past three years, FCPAméricas has posted summaries of the views that lead FCPA enforcement officials provide at ACI’s International Conference on the FCPA (see posts from 2011, 2012, and 2013). This year, at the 2014 conference, Kara Brockmeyer (Chief of the FCPA Unit of the SEC’s Enforcement Division) and Patrick Stokes (Deputy Chief of the FCPA Unit of the Fraud Section of the DOJ’s Criminal Division) offered helpful insights (these were their views and not the official views of their res... Read more


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