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

Description

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.