FCPAméricas Blog
Ten Rules for Effective Internal Investigation Interviews
2.08.2012
Conducting interviews is a vital skill for internal FCPA investigators. After reviewing endless emails, technical memos and accounting ledgers, we almost always have to speak directly to someone in order to run potential FCPA violations to ground. Often, the primary objective of such interviews is to elicit as much information as possible about the underlying […]
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The Anatomy of Corruption in Public Procurement
1.17.2012
Public procurement presents significant risk under the U.S. Foreign Corrupt Practices Act (FCPA). Cases like Siemens Argentina, Siemens Venezuela, Johnson & Johnson, and Tenaris highlight the risk. Large amounts of money are at stake when the government procures things like roads, computer systems, oil extraction services, medical equipment, power stations, and textbooks. Companies must interact directly […]
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Cultural Considerations and the FCPA: Part 2 (Compliance)
12.22.2011
Do considerations of culture have a place in the FCPA? Yes and no – it depends on the context. Part 1 of this blog post discusses culture’s role in enforcement. Part 2 (below) discusses its role in compliance. Part II. Compliance. While cultural norms have no relevance in enforcement (see Part 1), they have an important […]
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Cultural Considerations and the FCPA: Part 1 (Enforcement)
12.20.2011
Do considerations of culture have a place in the FCPA? Yes and no – it depends on the context. Part 1 (below) of this blog post discusses culture’s role in enforcement. Part 2 discusses its role in compliance. Part I. Enforcement. In FCPA enforcement, cultural norms are irrelevant. It does not matter to law enforcement […]