This article was republished with permission from FCPAméricas Blog, for which Matteson Ellis is founder, editor and regular contributor.
FCPAméricas recently interviewed Bruce Horowitz, a lawyer in Ecuador who conducts considerable anti-corruption compliance work and understands the local terrain. Mr. Horowitz has served as Co-Chair of the ABA’s Anti-Corruption Committee and is currently launching the Center for the Study of Bribery and Extortion Situations in Ecuador.
In the interview, Mr. Horowitz shared his thoughts on managing corruption risks in Ecuador:
“Something that people should do and companies should do when they come here is talk and find out what government offices that they’ll have to work with have people who extort … [G]et to know each office and the people in each office. Individuals do different things and there are people who don’t ask for bribes and there are people who do ask for bribes and usually it is not difficult to find out who’s who.”
“[When facing corruption-related delays at the courts,] filing something in writing and going back to the courthouse over and over and over again and filing complaints with judicial counsel does work because judges are noticing that other judges are being fired because they are not getting the work done.”
“Be sure that all your paperwork is correct and that you file things on time.”
“People know other people and it goes all the way through society and it really is not based on class. It has to do with friendships and family systems … this is one of the ways you can stop … their demand for a bribe because you know someone who is a friend of theirs or they are in a hierarchy above the person who is demanding the bribe, so the word gets back to that person who is demanding a bribe and will or may stop.”
“What you always have to remember is, if you can’t get what you want without paying the bribe, then you finally do have to walk away, but you don’t have to walk away at the first sign of a bribe demand.”
The opinions expressed in this post are those of the author in his or her individual capacity and do not necessarily represent the views of anyone else, including the entities with which the author is affiliated, the author`s employers, other contributors, FCPAméricas or its advertisers. The information in the FCPAméricas blog is intended for public discussion and educational purposes only. It is not intended to provide legal advice to its readers and does not create an attorney-client relationship. It does not seek to describe or convey the quality of legal services. FCPAméricas encourages readers to seek qualified legal counsel regarding anti-corruption laws or any other legal issue. FCPAméricas gives permission to link, post, distribute or reference this article for any lawful purpose, provided attribution is made to the author and to FCPAméricas LLC.
Matteson Ellis serves as Special Counsel to the FCPA and International Anti-Corruption practice group of Miller & Chevalier 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 
