FCPAméricas Blog
FCPA Compliance for SMEs: How smaller companies meet enforcement agency expectations
5.09.2014
FCPA compliance expectations for multi-national corporations (MNCs) are relatively clear. Enforcement authorities regularly describe them in FCPA resolutions and public statements, and FCPAméricas provides its own overview here.
But how should small- and medium-sized enterprises (SMEs) apply these standards, especially smaller companies that still have significant corruption risk profiles? SME’s resources, personnel, and capacity are usually much more limited that those of MNCs. Does a privately held oil and gas services company with 100 employees in Texas and 250 on-site in Angola need a stand-alone compliance officer? How robust a third party ... Read more
How Top-Level Management Shows FCPA Compliance Commitment
5.02.2014
One of the most important elements of an effective FCPA compliance program is top-level commitment, what might be called “tone from the top.” Those at the top of an organization are in the best position to foster a culture of compliance. As indicated in the FCPA Guidance, the DOJ and SEC “consider the commitment of corporate leaders to a culture of compliance” when assessing compliance programs.
There are practical steps that top-level management can take to demonstrate commitment to FCPA compliance. This post highlights four.
<... Read moreImpact of the FCPA and UK Bribery Act in Latin America: Perspectives from Argentina, Mexico and Brazil
4.30.2014
What impact have the FCPA and the UK Bribery Act had outside the US and the UK? I put that question (and a few others) to prominent anticorruption attorneys in five Latin American countries. All reported local impacts from these two foreign laws, but the nature of those impacts varied in significant and interesting ways. In a previous post, I summarized answers received from attorneys in Chile and Venezuela. This post summarizes responses from counsel in three of Latin America’s economic heavyweights: Argentina, Mexico and Brazil.
Argentina
