FCPAméricas Blog

The Language of Bribery in Latin America

Author: Guest Author

LanguageThis post was co-authored by Leah Moushey, an associate at Miller & Chevalier.

To run an effective FCPA compliance program in Latin America, it is important to know the terms and phrases used locally to describe bribery. This helps companies identify corruption risks and respond with appropriate compliance strategies. Compliance trainings in the region are more effective when corruption risks can be explained using familiar terminology. Compliance audits and internal investigations can use local bribery terminology in electronic document searches to identify problematic issues.

As part of the 2016 Latin America Corruption Survey, released by Miller & Chevalier and 13 partner law firms throughou... Read more

Anti-Bribery in Brazil: 2016 Year in Review

Author: Carlos Ayres

BrazilYearinReviewA lot has been going on in Brazil in the anti-bribery field. There have been different developments that are noteworthy. This post highlights 5 relevant developments that took place in 2016. Other relevant developments will be summarized in the next post.

Car Wash continues to advance. The Operation Car Wash was initially launched in March 2014. In 2016 alone, 17 special operations were carried out by the Federal Prosecutors task force and 20 criminal charges were filed in connection with corruption, money laundering, conspiracy, and related crimes. In 2015, 15 special operations were carried out and 15 criminal charges were filed. In 2014, 8 special operations were carried out and 17 criminal charges were filled. In total, as of December 2016, the Car Wash resulte... Read more

Whistleblowers: 2016 Year in Review

Author: Carlos Ayres

WhistleblowerThe SEC 2016 Annual Report to Congress on the Dodd-Frank Whistleblower Program was published on November 15, 2016. This post highlights seven relevant aspects of the report.

Continuous increase in number of tips received by the SEC. The number of whistleblower tips the Commission receives annually continues to increase: 3,001 tips in the 2012 fiscal year, 3,238 tips in the 2013 fiscal year, 3,620 tips in the 2014 fiscal year, 3,923 tips in the 2015 fiscal year and 4,218 tips in fiscal year 2016. From fiscal year 2012, the first year for which we have full-year data, to fiscal year 2016, the number of whistleblower tips has grown more than 40 percent. Since August 2011, when the SEC’s O... Read more


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