May 23, 2012 | Inside Counsel
Regulatory: Challenging the government’s broad interpretation of “foreign official” under the FCPAAt the crux of almost every Foreign Corrupt Practices Act (FCPA) internal investigation or government enforcement action involving alleged bribery is the question of whether the individual being allegedly bribed is a foreign official pursuant to the FCPA.
By Jaime Guerrero
7 minute read
May 09, 2012 | Inside Counsel
Regulatory: The risk of cooperating with the government during an internal investigationThe Department of Justice (DOJ) provides guidance onand incentives forcompanies that cooperate with the government and self-report any alleged misconduct on behalf of the company and its employees.
By Jaime Guerrero
7 minute read
April 25, 2012 | Inside Counsel
Regulatory: 7 points to consider in regard to FCPA due diligenceFocus on the acts of joint venture partners and agents
By Jaime Guerrero
4 minute read
April 11, 2012 | Inside Counsel
Regulatory: Brazil’s changing regulatory windsMultinational companies and their executives operating in Brazil have increased cause to tread carefully with respect to anti-corruption compliance.
By Jaime Guerrero
3 minute read
March 28, 2012 | Inside Counsel
Regulatory: Most SEC whistleblowers tell company firstSean McKessy, Chief of the Securities and Exchange Commission's (SEC) Office of the Whistleblower, recently reported that a significant majority of whistleblowers indicated that they used internal reporting channels before contacting the SEC.
By Jaime Guerrero
4 minute read
March 14, 2012 | Inside Counsel
Regulatory: Establishing an effective FCPA and anti-corruption compliance program in Latin AmericaOver the past few years, U.S. government enforcement agencies have substantially increased the number of investigationsand resulting enforcement actionsof companies and individuals in Latin America over alleged violations of the Foreign Corrupt Practices Act (FCPA).
By Jaime Guerrero
3 minute read
July 27, 2011 | Daily Business Review
Board of Contributors: Knowledge of language, culture key in Latin America FCPA probesFor U.S. multinational companies operating in Latin America, the challenge of responding to a Foreign Corrupt Practices Act inquiry is compounded by the challenges inherent in conducting operations in multiple countries with multiple languages.
By Jaime Guerrero and Rob Iseman
4 minute read
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