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Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

Compliance as a Valuable Tool for Avoiding Enforcement Action in Mexico and Latin America

The Recent Focus on Corruption in Mexico - On July 19, 2017, the General Law of Administrative Responsibilities (GLAR) went into effect in Mexico, making it a “serious administrative offense” for individuals and companies...more

Significant Changes In Anti-Bribery Laws In Mexico And Colombia Signal A New Commitment To Anti-Corruption Efforts

For companies with global operations, the Foreign Corrupt Practices Act (FCPA) is no longer the only anticorruption law of significance. Mexico and Colombia recently enacted sweeping anti-corruption legislation aimed at...more

Brazil Enacts Anti-Corruption Law

Companies doing business in the country should evaluate their compliance programs to avoid the law's sanctions on violators. On August 2, Brazilian President Dilma Rousseff signed Law No. 12,846/2013—unofficially...more

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