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FCPA Compliance in Latin America 2022: Implementing Compliance Programs and Mitigating Legal Risks

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, February 16, 2022

Recorded event now available

or call 1-800-926-7926

This CLE course will guide lawyers and compliance professionals 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 continue their efforts to enforce the Foreign Corrupt Practices Act (FCPA) with U.S. and foreign companies doing international business. Recent FCPA cases involving business activities in Latin American countries underscore the need for companies to implement or strengthen their compliance programs in response to increased scrutiny of U.S. companies' dealings with overseas officials.

Since the pandemic, many cases have been investigated and resolved by U.S. regulators involving companies operating in Latin America. For example, In late 2020, São Paulo–based conglomerate J&F pleaded guilty to a conspiracy charge for violating the FCPA and agreed to pay a $256 million fine. Further, Vitol Inc. agreed to pay a combined $135 million to resolve a DOJ investigation into FCPA violations along with a parallel investigation in Brazil.

As U.S. businesses move more aggressively into emerging markets throughout Latin America, counsel must act to ensure companies’ personnel and third parties in Latin America avoid violating U.S. laws or fall prey to a "when in Rome" attitude and its potentially 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 presenters will outline best practices for mitigating the risk of FCPA violations.



  1. Enforcement/lessons learned from recent government actions
  2. Risk factors for doing business in Latin America
    1. Latin American business culture/practices
    2. Broad definition of foreign official
    3. Exposure to third parties' FCPA violations
    4. Regional anti-bribery laws/local laws
    5. Reach of the FCPA
  3. Anti-corruption developments in Latin American countries
  4. Mitigating FCPA risks
    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 for companies conducting business in Latin America make them more vulnerable to FCPA violations?
  • What conduct has triggered SEC and DOJ investigations into potential FCPA violations?
  • What are the critical lessons from recent SEC and DOJ enforcement actions against companies doing business in Latin American countries?
  • What are best practices for 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

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

Pinedo, Wilby
Wilby Cáceres Pinedo

Deputy, Integrity and Compliance Officer
Newmont Corporation

Mr. Cáceres Pinedo is a member of Newmont’s Corporate Business Integrity and Compliance Team with...  |  Read More

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