FCPA Compliance in Latin America 2017: Implementing Compliance Programs and Mitigating Legal Risks

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, February 22, 2017
Recorded event now available

This CLE webinar will provide guidance to counsel for U.S. companies doing business in Latin America on implementing and strengthening Foreign Corrupt Practices Act (FCPA) compliance programs. The panel will review recent government enforcement focused on Latin American operations and the unique FCPA challenges when doing business in these countries.


The SEC and DOJ have vowed to continue vigorous efforts to enforce FCPA compliance by U.S. companies doing business overseas. Several recent FCPA cases involving business activities in Brazil, Panama, Argentina and Mexico underscore the need for companies to implement and/or strengthen their compliance programs in response to increased scrutiny of U.S. companies’ dealings with overseas officials.

Brazil’s new Anti-Bribery law, effective 2014, put in place a system to hold companies and individuals liable for corrupt acts involving Brazilian and foreign officials and governments. Other Latin American countries, including Peru, Colombia, Chile and Mexico, have also made efforts to hold corporate entities liable for corrupt acts of their directors, managers, employees and agents.

As U.S. businesses move more aggressively into emerging markets throughout Latin America, counsel must act to ensure their staff and contractors in Latin America avoid violating U.S. laws or fall prey to a “when in Rome” attitude and its potential costly consequences.

Listen as our authoritative panel discusses the risks of FCPA violations in Latin America and the lessons learned from recent enforcement actions. The panel will outline best practices for mitigating the risk of FCPA violations.


  1. What is happening in enforcement/lessons learned from recent enforcement
  2. Risk factors of doing business in Latin America
    1. Latin American business culture/practices
    2. Broad definition of foreign official
    3. Exposure to third party you may not control
    4. Regional anti-bribery laws/local laws
    5. Reach of the FCPA
  3. Anti-corruption developments in Latin-American countries
    1. Brazil
    2. Peru, Mexico and Chile
  4. Best practices for mitigating risk (how to compete effectively while complying with the FCPA)
    1. Compliance program—anti-bribery and accounting provisions
    2. Strengthening an existing compliance program in response to heightened scrutiny
    3. Education/training adapted to local conditions
    4. Due diligence—all third parties
    5. Steps if misconduct is suspected


The panel will review these and other key issues:

  • What risk factors make companies conducting business in Latin America more vulnerable to possible FCPA violations?
  • What types of conduct have triggered SEC and DOJ investigations into potential FCPA violations?
  • What are the key lessons from recent SEC and DOJ enforcement efforts aimed at companies doing business in Latin American countries?
  • What are the best practices to develop and implement effective anti-corruption compliance programs and due diligence efforts?


Matteson Ellis, Member
Miller & Chevalier, Washington, D.C.

Mr. Ellis has extensive experience in all areas of international anti-corruption compliance and enforcement. With a focus on the Americas, he advises companies and individuals on all areas of FCPA enforcement and compliance. He has performed complex, independent, and on-site internal investigations in over 20 countries throughout the Americas, Asia, Europe, and Africa.

Matthew J. Feeley, Shareholder
Buchanan Ingersoll & Rooney, Miami

Mr. Feeley focuses his practice on international commercial litigation with particular emphasis in FCPA and complex civil matters. He advises on conducting internal investigations, designing and implementing compliance programs, and asserting, responding to and defending against federal, state and international civil and criminal proceedings, investigations, prosecutions and trials.

Jay Holtmeier, Partner
Wilmer Cutler Pickering Hale and Dorr, New York

Mr. Holtmeier co-leads the firm's FCPA and Anti-Corruption Group and is a member of the Dodd-Frank Whistleblower Working Group. He represents institutions and individuals in complex government and internal investigations and matters of corporate governance and compliance with particular expertise in matters involving the FCPA. He regularly counsels clients facing difficult FCPA issues in a variety of business contexts, and he has assisted clients in numerous industries in developing and implementing FCPA compliance programs. He devotes substantial attention to advising clients on FCPA problems that arise in the context of mergers and acquisitions, joint ventures and other corporate transactions.


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Customer Reviews

I appreciated the personal-level insights of the speakers.

Kendall Carter

King & Spalding

The speakers' presentations were very substantive and provided new information for seasoned practitioners.

Therese Lee


The topics were timely and the discussion level was appropriate for non-lawyers and practitioners who are not FCPA specialists.

Anne Turner

Baker Donelson

I appreciate the mix of legal instruction to real-world advice and that all of my questions going in were answered by the prepared remarks.

Michael Hoff

MTS Systems

All of the speakers were very informative, and being able to ask questions was very helpful.

Larry V. Smith

Jackson Walker

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International Law Advisory Board

Edward J. Fishman



Judith A. Lee


Gibson Dunn & Crutcher

Greta Lichtenbaum


O’Melveny & Myers

Kimberly A. Parker



Kyle A. Wombolt


Herbert Smith

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