FCPAméricas Blog
Tips for Latin American Companies Partnering with the Chinese – Embrace Compliance
3.27.2014
The following is a guest post from Gregory Shultz, the Founder of China-based “The Compliance Table.”
With the latest anti-corruption enforcement developments in China, Chinese companies are quickly being exposed to international compliance standards. This creates an opportunity for others doing business with the Chinese throughout the world to incorporate anti-corruption strategies into their own business plans. This is particularly relevant in Latin America, given the huge growth of Chinese investment there.
It is helpful to summarize certain global trends. The world is anxiously awaiting signs of economic growth in the world’s top economies, as it has done for the last six years. While most countries marvel at growth... Read more
Best Practices for FCPA Investigation Document Holds – Part II
3.25.2014
Companies should take affirmative steps to ensure relevant documents are preserved when an allegation of a potential FCPA violation is made. This often results in the issuance of a timely document hold memorandum to relevant employees.
An earlier post describes the definition of the proper scope of the notice, who should receive it, routine documentation practices, and the category of documents to be obtained. This post discusses other important issues to consider.
Define the best time to send the hold. In general, document holds should be issued as soon as employees who may have relevant... Read more
Best Practices for FCPA Investigation Document Holds
3.20.2014
Once an allegation of a potential FCPA violation has been made, companies should investigate it and fully document their work. The preservation of relevant documents as early as possible is one of the most important steps to a credible investigation.
The exact steps to be taken to preserve documents will depend on a number of factors, including the scope of the investigation and the size of the company. They will almost always include the issuance of a “document hold.” This is a formal communication to employees who may have relevant information stating that they should not destroy any documents related to a specific matter until further notice.
Document holds are a basic expectation ... Read more
