One of the most innovative features of Brazil’s new Anti-Bribery Law is Chapter 5, which establishes the possibility of leniency agreements for companies. This is a new concept in Brazil’s anti-corruption arena.
Surprisingly, the number of FCPA resolutions that actually involved the Asia-Pacific region sharply declined in 2013, against trend and in apparent contradiction of ubiquitous enforcement attention and coverage.
There has been considerable discussion over the last few years about anti-corruption developments in Brazil, Mexico, Argentina and Colombia. But what about the fifth OECD member state in the region – Chile?
Sasha Kalb and Marc Bohn of Miller & Chevalier provide an in-depth examination of the SEC's application of disgorgement - the remedy used to deprive wrong-doers of their ill-gotten gains and deter violations of federal securities law - in FCPA resolutions.