Matteson Ellis

Matteson Ellis serves as Special Counsel to the FCPA and International Anti-Corruption practice group of Miller & Chevalier Chartered in Washington, DC.  He is also founder and principal of Matteson Ellis Law PLLC, a law firm focusing on FCPA compliance and enforcement. He has extensive experience in a broad range of international anti-corruption areas. Previously, he worked with the anti-corruption and anti-fraud investigations and sanctions proceedings unit at The World Bank.

Mr. Ellis has helped build compliance programs associated with some of the largest FCPA settlements to date; performed internal investigations in more than 20 countries throughout the Americas, Asia, Europe and Africa considered “high corruption risk” by international monitoring organizations; investigated fraud and corruption and supported administrative sanctions and debarment proceedings for The World Bank and The Inter-American Development Bank; and is fluent in Spanish and Portuguese.

Mr. Ellis focuses particularly on the Americas, having spent several years in the region working for a Fortune 50 multinational corporation and a government ethics watchdog group. He regularly speaks on corruption matters throughout the region and is editor of the FCPAméricas Blog.

He has worked with every facet of FCPA enforcement and compliance, including legal analysis, internal investigations, third party due diligence, transactional due diligence, anti-corruption policy drafting, compliance training, compliance audits, corruption risk assessments, voluntary disclosures to the U.S. government and resolutions with the U.S. government. He has conducted anti-corruption enforcement and compliance work in the following sectors: agriculture, construction, defense, energy/oil and gas, engineering, financial services, medical devices, mining, pharmaceuticals, gaming, roads/infrastructure and technology.

Mr. Ellis received his law degree, cum laude, from Georgetown University Law Center, his masters in foreign affairs from Georgetown’s School of Foreign Service, and his B.A. from Dartmouth College. He co-founded and serves as chairman of the board of The School for Ethics and Global Leadership in Washington, D.C. He is a member of the District of Columbia, Texas, New York, and New Jersey bar associations.

Mr. Ellis is also author of The FCPA in Latin America: Common Corruption Risks and Effective Compliance Strategies for the Region.

hand holding whatsapp icon on pink background

Matteson Ellis describes what a compliance policy for ephemeral communications should look like – a concern for Latin American countries in particular, where WhatsApp is used widely. Perhaps in no region of the world is WhatsApp used more frequently than in Latin America. From Mexico to Patagonia, people rely on the application constantly for both personal and professional use. With this new...

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colombian president Juan Manuel Santos

How "Supersociedades" is Doing in Battling Corruption Matteson Ellis summarizes developments with respect to Colombia’s Superintendent for Corporate Entities (Supersociedades). Numerous investigations are underway, sanctions have been levelled and the country’s leaders are speaking out in no uncertain terms to condemn wrongdoing. Recent announcements in Colombia indicate that the country is taking seriously its new transnational bribery law. Colombia’s Superintendent for Corporate Entities...

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Mexican flag against a blue sky

Organizations doing business in Mexico well do well to remain up to speed on the country’s National Anti-Corruption System (the SNA). Mexico remains one of the highest-risk jurisdictions in the Americas, an ignoble distinction it’s held for several years. The SNA is, therefore, a welcome development to organizations unwilling to participate in the corruption so prevalent in the region.

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The FCPA in Latin America

Despite the occasional high-profile FCPA investigation, we’ve seen an overall downward trend in FCPA violations. This could be attributable largely to a broader awareness of the FCPA among LatAm corporations. According to results from the 2016 Latin America Corruption Survey, awareness of the FCPA is up. Matteson Ellis details the findings.

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Recent FCPA action reveals significant risks

It’s easy to see issues in retrospect, but in many cases involving FCPA enforcement actions, there are plenty of red flags along the way. Take, for instance, the recent action against Key Energy in Mexico: the company overlooked a number of risk indicia; $5 million in profit disgorgements later, and those compliance missteps without a doubt don’t appear quite so minor.

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Corruption is endemic in Brazil

Brazil’s “Lava Jato,” or “Operation Car Wash” is a federal investigation into allegations of corruption at Petrobras. And it’s the most expansive anti-corruption investigation in the world today. Speaking earlier this summer on the topic of handling political corruption cases in Brazil, Judge Sergio Moro discussed the enormous costs of systemic corruption.

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Tips to avoid FCPA violations in port

Are your employees trained and equipped to respond appropriately to bribe demands? Matteson Ellis outlines the steps one company took to deal with (false) allegations of compliance violations. Because this organization had an effective anti-corruption policy in place and because its staff could easily recognize a shakedown, they were able to swiftly escalate the situation.

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Strategies to mitigate extortion risk in Latin America

Unfortunately, bribery and extortion aren’t uncommon in Latin America. Organizations may be relieved to know that payments made to government officials under the threat of extortion or duress will not give rise to FCPA liability. But that doesn’t mean the payments won’t otherwise trigger an FCPA violation. So how do businesses ensure compliance in such challenging situations?

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the biggest issues compliance staff must overcome in FCPA investigations

Latin America is experiencing a significant rise in the number of internal investigations at large corporations, an increase that is likely due in part to the DOJ’s Pilot Program, which focuses on holding individuals accountable for wrongdoing. Here are some of the key issues these companies face as they conduct internal investigations in the region.

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