Observing the U.S. government’s increased investigations of companies and individuals in Latin America over alleged violations of the Foreign Corrupt Practices Act (FCPA), Partner Jaime Guerrero discusses the need for multi-national companies operating in Latin America to establish effective compliance programs that may help them avoid FCPA penalties. He states that the varied political and socio-economic conditions in each of the Latin American countries creates a fluctuating risk of potential FCPA violations from country to country, adding that these conditions must be properly understood to gauge the effectiveness of a company’s anti-corruption compliance program.
