FCPA Compliance: 5 Overlooked Issues

FCPA Compliance: 5 Overlooked Issues

1. Single Compliance Program: A “one size fits all” compliance program does not often work. Must take into account risk/cultural aspects of every country and have a proportionate global program. Must be able to demonstrate compliance program works effectively and has been tested: Prevent-Detect-Respond. Materiality does not matter, issue is whether your internal control system works effectively to detect and avoid illegal payments. 2. Unsupervised 3Ps: Largest source of FCPA violations comes from third parties (3Ps): Agents, Distributors,…
Read More
Orihuela Abogados | Attorneys at Law

Orihuela Abogados | Attorneys at Law

Orihuela Abogados | Attorneys at Law was founded in July 2007, as a boutique law firm primarily dedicated to advising international clients doing business in Peru and in Latin America. Over the years our firm gained important expertise on complex M&A transactions involving mining, pharmaceutical and general corporate matters. Due to the increasing international enforcement of anti-corruption regulations from the U.S., Canada and the U.K., as well as the enhancement to local laws underway in Brazil,…
Read More
‘My work is part of something bigger’, Sandra Orihuela writes in the FCPA blog

‘My work is part of something bigger’, Sandra Orihuela writes in the FCPA blog

As I settle back at my desk in Peru, I reflect on my experience last week at the IACA’s Corporate Integrity Training program. Ten years ago I wouldn't have imagined sharing a room with people from 25 different countries to discuss anti-corruption compliance. Our topic has gone global like never before. My concerns as a compliance attorney in Peru and Miami are like those of the government official from Cameroon, the prosecutor from Quebec, the…
Read More