BY CHRONICLE STAFF
What advice do you give companies just starting operations in Latin America on how to avoid violating the FCPA? What advice do you give companies that acquire firms that operate in Latin America that may have violated the FCPA? Have U.S. companies become more aware of the danger of violating the FCPA in Latin America compared to earlier? Has there been an increase in FCPA cases in Latin America in the past year or past two years?
Latin Business Chronicle asked a group of experts. Our panel:
- Marta Alfonso, CPA/CFF, JD, partner in the Litigation Support Department of Morrison, Brown, Argiz & Farra
- Sam Danon, Partner, Litigation & Intellectual Property Practice, Hunton & Williams
- Matthew Feeley, Shareholder, Buchanan Ingersoll
- Simon Strong, Senior Managing Director, Forensic and Litigation Consulting, FTI
Latin Business Chronicle: What advice do you give companies just starting operations in Latin America on how to avoid violating the FCPA?
Alfonso: A company starting operations in Latin America should establish a clear policy that it will fully comply with FCPA provisions and anti-corruption and anti-money laundering laws both from the United States and in country, including the OAS Inter-American Convention Against Corruption. To support the policy, it should establish a set of FCPA compliance policies and procedures for the types of transactions and relationships it undertakes in Latin America (including those with customers, suppliers, employees, and regulatory officials). These FCPA compliance policies and procedures should include ....