FCPA compliance


Highway 61 and IRS Involvement in FCPA Enforcement

If you need a reason to bolster your monitoring efforts, you may find the recent FCPA enforcement action against Vicente Eduardo Garcia to be quite instructive. One noteworthy feature of this investigation was the involvement of the IRS’s Criminal Investigation unit, the lesser-discussed of the DOJ’s two investigative bodies, called in to comb through mountains of data and ...


Farewell to Chocolate Thunder, Baylor Football and Due Diligence

Just as the football season kicks off, Baylor University is embroiled in scandal. One of the football team's prized recruits was recently convicted of sexual assault. Part of the trouble here is that the university doesn't seem to have done its homework on the athlete. When the story of his conviction broke, the finger pointing began. ...


Hiring Practices: A New or Old FCPA Compliance Challenge?

Is it possible to hire a relative of a foreign official AND remain compliant with the FCPA? Of course. But an organization making this sort of hire had better make sure each step in the process is above board. There are red flags to watch for and specific considerations to bear in mind, but when the ...

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Multi-Party Conspiracies in Central America: The Latest FCPA Case

The recent FCPA investigation and enforcement action against Vicente Eduardo Garcia, a former executive at SAP International, revealed an individual intent on circumventing internal controls, one who knew the illegality of his actions and went to great lengths to disguise them. Lessons for the compliance practitioner? For starters, violations can occur without actual payments.

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A Boost in FCPA Declinations? Why FCPA Enforcement Has Fallen This Year

The number of FCPA declinations is on the rise, while the number of enforcement actions is at its lowest level in more than a decade. Now, this doesn't mean companies and individuals suspected of corruption are getting away with anything; instead, the drop in enforcement actions could have everything to do with the fact that the subjects of ...

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Latin America’s Most Common Reaction to the FCPA

It seems unjust to some to be on the receiving end of American investigation or prosecution of bribery when the U.S. has its own issues with bribery. As a U.S. citizen enforcing American regulations on foreign soil, Matt Ellis has encountered this argument many times, and he's found several ways to respond to the complaint so as to legitimize ...

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The Sigelman Case and the DOJ’s FCPA Trial Record

Some are foaming at the mouth about the outcome of the FCPA trial of former PetroTiger CEO Joseph Sigelman. However, while the Department of Justice isn't overjoyed with how the case turned out, the outcome isn't at all unusual. The key takeaway here: you win some, you lose some. Will the DOJ overhaul it's FCPA enforcement ...


Corruption Scandals in…Chile?

Chile has historically ranked among the least corrupt countries in Transparency International's Corruption Perceptions Index, but past performance isn't always a great indicator of future results. Recent scandals in the country serve as an excellent reminder that corruption can rear its ugly head anywhere, even in areas not typically associated with bribery and improper conduct.

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FIFA, the DOJ and the Global Fight Against Corruption

The first step to recovery is admitting you have a problem. Let's grab onto that metaphor. Despite corruption that's been endemic for years, FIFA has not only not yet taken that first step, the organization is still balancing precariously on wobbly legs. With the DOJ having recently charged more than a dozen FIFA officials, however, the ...