Top 10 Anti-Corruption Red Flags In Latin America (Video …

The article by Rajal Dubal and Adam Tymowski, AlixPartners
LLP, and
Nicholas Berg
David Rojas
, Ropes Gray LLP, was originally published in
Law360 on July 5, 2016.

Latin American countries continue to be a source of potentially
lucrative investment opportunities for U.S. and multinational
corporations. At the same time, operating in Latin America may
present corruption-related challenges under the U.S. Foreign
Corrupt Practices Act.1 Identifying corruption under the
FCPA, however, is often not as easy as catching culprits in a
red-handed exchange involving envelopes teeming with cash. Rather,
symptoms of these issues are often identified through commonly
observed violations of the FCPA’s books-and-records and
internal-controls provisions.2

This article highlights 10 red flags related to the FCPA’s
accounting provisions, as well as enforcement actions undertaken by
the U.S. Securities and Exchange Commission and U.S. Department of
Justice for conduct occurring in the region.

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