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

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Course Materials

This CLE course 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?


Ellis, Matteson
Matteson Ellis

Miller & Chevalier

Mr. Ellis has extensive experience in all areas of international anti-corruption compliance and enforcement. With a...  |  Read More

Matthew J. Feeley
Matthew J. Feeley

Buchanan Ingersoll & Rooney

Mr. Feeley focuses his practice on international commercial litigation with particular emphasis in FCPA and complex...  |  Read More

Holtmeier, Jay
Jay Holtmeier

Wilmer Cutler Pickering Hale and Dorr

Mr. Holtmeier co-leads the firm's FCPA and Anti-Corruption Group and is a member of the Dodd-Frank Whistleblower...  |  Read More

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