Foreign Corrupt Practices Act in Brazil

Implementing FCPA Compliance Programs and Mitigating Risk

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

Conducted on Thursday, February 4, 2010
Recorded event now available

This CLE webinar 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.


Brazil has the largest economy in Latin America, is a critical U.S. trading partner and key member of the Mercosur Regional Trade Agreement, and will host the Olympics in 2016. These factors, along with increased SEC and DOJ scrutiny, require that companies focus on their FCPA compliance in Brazil.

As businesses compete for the lucrative contracts associated with the Olympics and to develop and conduct business in Brazil, they must anticipate, and act to minimize, the risk of FCPA violations.

Listen as our authoritative panel of FCPA attorneys with experience in Brazil examines the risks of FCPA violations in Brazil, discusses lessons learned from recent enforcement action, and outlines best practices for mitigating the risk of FCPA violations.


  1. Lessons learned from recent enforcement
  2. Risk factors of doing business in Brazil
    1. Business culture/practices
    2. Broad definition of foreign official
    3. Cooperation between U.S. companies and Brazil when conducting due diligence
    4. Exposure to third party you may not control
    5. Regional anti-bribery laws
    6. Reach of the FCPA
  3. Best practices for mitigating risk (how to compete effectively while complying with the FCPA)
    1. Monitoring
    2. Compliance program — anti-bribery and accounting provisions
    3. Internal controls
    4. Education/training adapted to local conditions
    5. Due diligence — all third parties
    6. 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?


Helen Harris, Partner
Day Pitney, Stamford, Conn.

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.

Kimberly A. Parker, Partner
WilmerHale, Washington, D.C.

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."

Edward J. Fishman, Partner
K&L Gates, Washington, D.C.

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.


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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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