FCPAméricas Blog
OECD Survey on Business Integrity and Corporate Governance
3.20.2015
The Organisation for Economic Cooperation and Development (OECD) is conducting a Survey on Business Integrity and Corporate Governance as part of a new initiative called the OECD Trust and Business (TNB) Project. The newly initiated TNB Project is working with governments, business, and civil society to promote a discussion about the effective integration of business integrity considerations into a company’s decision making.
The Project approaches this challenge by focusing on the roles and responsibilities of the board and executive management (as defined in the OECD Principles of Corporate Governance) in ensuring thei... Read more
The United States Sanctions Venezuela (and the sanctions are expected to broaden)
3.17.2015
The 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.
Two weeks ago, the Venezuelan government took action directed toward the United States, expelling most U.S. Diplomats from the country and requiring Americans to get visas to enter Venezuela. In response, on March 7, 2015, President Obama entered an executive order that blocked the property of seven high level Venezuelan officials, and suspended their ability to enter into the United States. The Executive Order contains a finding by the President that the current Venezuelan government has eroded human rights guarantees, persecuted political opponents, curtailed press fr... Read more
Investigating Oneself: Why Latin American companies should conduct internal reviews
3.12.2015
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
