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Enforcement activity in the first six months of the year was the lowest recorded in almost two decades. Similarly, last quarter, no companies disclosed a new FCPA-related investigation. The DOJ initiated a new pilot program to encourage self-disclosure by individuals · Download
The last several years has seen an ever-increasing focus on corruption in Latin America, in part due to major scandals and protests, all of which Latin American governments have had to account for in their corporate liability schemes.
Brendan Cullen, Partner in S&C's Litigation Group, and Tony Lewis, Co-Head of S&C's National Security Group, address these challenges in a chapter authored for Latin Lawyer's recently published Guide to Corporate Compliance. They provide guidance for multinational companies on how to build and maintain effective compliance programs, and summarize key risks that such corporations must address in their overall strategies.
They also discuss how the incorporation of best practices in companies' compliance programs can save them from considerable consequences later on. "It can prevent illicit conduct in the first place, it can detect it at the earliest possible stage if it does arise, and it can lessen or avoid many of the consequences that come with an enforcement action" they write · Download