This month, the DOJ's Lanny Breuer provided a direct response to the U.S. Chamber's call for an affirmative FCPA compliance defense. This article outlines the various components of that response…more
Last week, ACI held its 2012 National Conference on the U.S. Foreign Corrupt Practices Act where FCPA enforcement officials shared their current thinking. This article provides the highlights related to voluntary disclosures,…more
A recent video posted by the Markkula Center of Applied Ethics highlights one of the most difficult ethical issues facing FCPA compliance officers – doing your job when the CEO does not want you to. To provide some guidance on…more
Right now, Brazil is in the middle of its largest corruption trial in its history. The proceeding is being called the “Mensalão,” meaning “the big monthly payment.” Thirty-eight individuals, including current and former…more
As William Finnegan wrote recently in an illuminating New Yorker article, “in Mexico, it is often impossible to know who is behind something.” This is an important reminder for U.S. Foreign Corrupt Practices Act (FCPA)…more
The World Bank sanctions system has teeth. Just ask Oxford University Press, Alstom, KBR, and the more than eighty other companies and individuals debarred over the last year for violating the Bank’s Procurement Guidelines and…more
In yesterday's Orthofix settlement for FCPA violations in Mexico, the SEC said what some of us already knew. The use of local language is essential to "effective" FCPA compliance. This article provides examples of why it is…more
In January 2012, FCPAméricas reported on how Brazil is currently considering an overhaul of its foreign bribery law. In March, we reported on how a special committee created by the Brazilian Congress to analyze the bill made…more
General Counsel and Internal Compliance Officers get approached regularly by outside FCPA service providers. Given so many options, companies that are ready to enhance their FCPA compliance programs often do not know where to…more
Will the Wal-Mart bribery case in Mexico have a lasting effect on compliance? Or is it a fleeting headline? This article discusses some reasons they this FCPA case will matter…more
What is an FCPA compliance practitioner to make of the recent Wal-Mart de Mexico bribery allegations? This article lists eight insights into specific corruption risks raised by the matter…more
There are numerous reasons why the New York Times expose on Wal-Mart's bribery scheme in Mexico is notable. This article highlights a few of the important FCPA issues…more
A common challenge for companies getting up to speed on their FCPA due diligence programs relates to addressing their current business relationships. Even if a company has implemented procedures to vet new partners going…more
This map walks companies through the basic steps of an internal FCPA investigation. It provides detailed considerations at each phase. Companies should review the chart in detail and make sure their current processes capture…more
If Biomet had targeted its FCPA compliance efforts in these four areas, history would probably be much different…more
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