FCPAméricas Blog
What U.S. Companies Can Now Do In Cuba
3.05.2015
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. 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 busines... Read more
Ten FCPA Compliance Tips for Private Equity
2.27.2015
As 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 moreCorporate Investigations in Latin America, According to Jim Mintz
2.19.2015
FCPAméricas sat down recently with Jim Mintz, who runs the global investigations firm the Mintz Group, to get his thoughts on corporate investigations in Latin America.
Describe your approach to corporate investigations.
Lawyers and investigators begin each case knowing little or nothing about the subject company or issue. It’s like standing outside a high wall. We begin to look for cracks in that wall by doing our homework, talking to the client, gathering paper. And we find some doors in that wall. These cases are often so complex that, after we get through the outer wall, we then find ourselves at the outer layer of a maze of alleged wrongdoing inside a corporate environment. Our job is to work through this maz... Read more
