Foreign Corrupt Practices Act in Brazil
Implementing FCPA Compliance Programs and Mitigating Risk
Olympic preparation in Rio creates FCPA minefield
Recording of a 90-minute CLE webinar with Q&A
This CLE course will discuss recent FCPA enforcement focused on business activity in Brazil, discuss the particular FCPA challenges of conducting business there, and offer strategies for FCPA compliance in Brazil.
- Lessons learned from recent enforcement
- Risk factors of doing business in Brazil
- Business culture/practices
- Broad definition of foreign official
- Cooperation between U.S. companies and Brazil when conducting due diligence
- Exposure to third party you may not control
- Regional anti-bribery laws
- Reach of the FCPA
- Best practices for mitigating risk (how to compete effectively while complying with the FCPA)
- Compliance program — anti-bribery and accounting provisions
- Internal controls
- Education/training adapted to local conditions
- Due diligence — all third parties
- Steps if misconduct is suspected
The panel will review these and other key questions:
- What risk factors make companies conducting business in Brazil more vulnerable to possible FCPA violations?
- What types of conduct have triggered SEC and DOJ investigations into potential FCPA violations?
- What lessons can be learned from recent SEC and DOJ enforcement efforts aimed at companies doing business in Brazil?
- What strategies should companies and counsel employ to develop and implement effective anti-corruption compliance programs and due diligence efforts?
Her work involves government investigations and securities and other commercial litigation. She represents individuals... | Read More
Her work involves government investigations and securities and other commercial litigation. She represents individuals and companies in connection with investigations by regulatory agencies and federal and state authorities. She also represents companies in connection with securities class actions, commercial litigations, and internal corporate investigations of FCPA compliance.Close
Kimberly A. Parker
Ms. Parker regularly counsels clients on how to develop effective FCPA compliance programs, how to avoid potential... | Read More
Ms. Parker regularly counsels clients on how to develop effective FCPA compliance programs, how to avoid potential FCPA problems, and how to address FCPA problems when they arise. She also represents clients in internal investigations throughout the world. She co-authored the leading treatise in the field, "Complying With the Foreign Corrupt Practices Act."Close
Edward J. Fishman
Mr. Fishman advises clients with respect to government and internal corporate investigations, corporate transactions,... | Read More
Mr. Fishman advises clients with respect to government and internal corporate investigations, corporate transactions, and related regulatory matters. He focuses on FCPA compliance and auditor independence requirements. Mr. Fishman has extensive experience representing companies in connection with FCPA compliance, due diligence, training and other risk management procedures. He also regularly advises clients on matters before the DOJ and the SEC.Close