No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • CCI Magazine
    • Writing for CCI
    • Career Connection
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Library
    • Download Whitepapers & Reports
    • Download eBooks
    • New: Living Your Best Compliance Life by Mary Shirley
    • New: Ethics and Compliance for Humans by Adam Balfour
    • 2021: Raise Your Game, Not Your Voice by Lentini-Walker & Tschida
    • CCI Press & Compliance Bookshelf
  • Podcasts
    • Great Women in Compliance
    • Unless: The Podcast (Hemma Lomax)
  • Research
  • Webinars
  • Events
  • Subscribe
Jump to a Section
  • At the Office
    • Ethics
    • HR Compliance
    • Leadership & Career
    • Well-Being at Work
  • Compliance & Risk
    • Compliance
    • FCPA
    • Fraud
    • Risk
  • Finserv & Audit
    • Financial Services
    • Internal Audit
  • Governance
    • ESG
    • Getting Governance Right
  • Infosec
    • Cybersecurity
    • Data Privacy
  • Opinion
    • Adam Balfour
    • Jim DeLoach
    • Mary Shirley
    • Yan Tougas
No Result
View All Result
Corporate Compliance Insights
Home FCPA

Keeping Track of US Efforts to Stem Corruption at Home & Abroad

US enforcement priorities speak to rising tide of fraud overseas

by Susana Sierra
September 25, 2023
in FCPA
department of justice building

Reports show the spirit of anti-corruption in Latin America may be waning. But Susana Sierra of BH Compliance explores why recently shifted American enforcement priorities should cause all U.S. companies with Latin American connections to take note.

The global recovery from the pandemic and its consequences has not been easy. The millions of deaths, the weakening of the economy and the crisis deriving from high unemployment and lack of opportunities have been followed by a series of events that further complicate the operating scenario for multinational corporations.

Among all the world’s developing regions, Latin America was the most affected by the pandemic, and as a result, so were global companies operating there. According to data from the United Nations, in 2020 the Latin American economy contracted by 7.7% and almost 3 million companies folded, increasing unemployment and unreported employment.

This is just a small sample of the global consequences of this crisis, which continues to wreak havoc in Latin America, a region often characterized by vulnerability, where violence, drug trafficking and organized crime continue to increase their influence in the social and business spheres. These threats have increased the risks to the principles of corporate governance and have put more pressure on resources related to corporate compliance programs in Latin America and beyond.

In fact, the World Justice Project 2022 Global Rule of Law Index revealed that the rule of law declined in 61% of the countries surveyed, which means that 4.4 billion people live in countries where the rule of law is weaker than last year.

Additionally, the 2023 Anti-Corruption Capacity Index explores the capacity of 15 Latin American countries to detect, prevent and sanction corruption. The index shows the general Latin American anti-corruption environment is losing momentum, as governments are facing other challenges, such as violent crime, slow economic recovery and concerns about democratic backsliding.

In this scenario of crisis, mistrust and political instability, corruption has found fertile ground, which worries not only the region but the entire world, because in the current state of globalization and economic interdependence, whatever happens in one part of the globe can have effects everywhere else. 

US actions to curb corruption

Since his first year in office, President Joe Biden has been announcing ambitious measures to confront corruption in Latin America, which is seen — along with drug trafficking — as one of the main causes of the flow of migrants. In order to curb illegal immigration from the Northern Triangle (Honduras, Guatemala and El Salvador), the Biden Administration created the so-called Engel List, naming those linked to acts of corruption in said countries, who are prohibited, along with their families, from entering the U.S. 

Similarly, the Biden Administration has ramped up DOJ and SEC enforcement of the FCPA, announcing 14 corporate enforcement actions in 2022, an increase from just six actions the previous year, the lowest total in modern FCPA enforcement history. In addition, in 2022 the financial importance of these cases increased, with three investigations resulting in more than $100 million in combined penalties and restitution.

And the DOJ has continued to supercharge efforts to address corporate crime, including an effort to strengthen companies’ compliance programs  and offering incentives to self-report crime and fraud, as well as rewards for corporations with compliance-promoting compensation programs. These measures include an update to the agency’s corporate enforcement policy and “Evaluation of Corporate Compliance Programs,” introduction of a pilot program on compensation and clawbacks and publication of a revised memo on monitorships in Criminal Division matters.

brazil corruption protest
FCPA

Companies Ignore Cross-Cultural FCPA Competence at Their Own Peril

by Kenneth Johnson
August 1, 2023

The two main areas of FCPA focus are well-known, prohibitions against bribery and SEC accounting reporting. But as business development expert Kenneth D. Johnson argues, local cultural awareness is just as important — or should be.

Read moreDetails

All these measures are at the forefront in the prosecution of corporate crime, because they not only emphasize the idea that no company is above the law but also give companies great power — the responsibility to prevent and report corruption. This is key for those with operations in Latin America, where corruption continues to gain ground as the rule of law continues to weaken.

Although the new compliance measures under the Biden Administration are applicable only to U.S. companies, they should also be taken into consideration by Latin American companies and executives, since they could be investigated and sanctioned under the FCPA in the current scenario of globalization and international business.

For this reason, multinationals with operations in Latin America are called upon to strengthen their compliance programs and pay serious attention to the prevention of corruption and bad practices. A single rotten apple in an organization is enough to tarnish the reputation and good practices that they may have been carrying out for years.

Companies must understand that they have a social role beyond the creation of employment and their economic contribution. They must also concern themselves with being good corporate citizens and direct their actions toward the common good and the recovery of trust in institutions, which includes them. Preventing crime is one of the duties of the private sector and must be incorporated into their business strategies.


Tags: Anti-BriberyAnti-CorruptionDOJSEC
Previous Post

PayPal, Verizon Listed Among Transparency Award Winners

Next Post

How Companies Can Get Ahead Using FedNow

Susana Sierra

Susana Sierra

Susana Sierra is the CEO of BH Compliance, an enterprise that measures the effectiveness of corporate governance policies and processes. She is a global leader in the field of compliance and corporate governance, recognized for her influential work in promoting transparency, ethics and good practices in the private sector.

Related Posts

doj distorted

FCPA Enforcement Back on at DOJ — With a New Look

by Jennifer L. Gaskin
June 18, 2025

After a shorter-than-expected pause, officials with the DOJ have formally renewed the department’s enforcement of the FCPA. CCI’s Jennifer L....

doj exterior sign

How to Use the DOJ’s ECCP to Build (or Fix) Your Compliance Program

by Susan Divers
June 5, 2025

Corporate compliance programs face increasing scrutiny as the DOJ applies its evaluation framework across industries and company sizes, from multinational...

disruption concept logs split

The Devil You Know …

by Carrie Pallardy
June 4, 2025

With compliance processes driven largely by regulatory requirements, the financial services sector could be forgiven for breathing a sigh of...

doj sign front

Assessing the Business Risks of the Trump Administration’s ‘Total Elimination’ Strategy

by José Cortina and Jennifer Christian
May 20, 2025

As cartels increasingly participate in mainstream economic activities, traditional due diligence practices become inadequate to address new material support risks

Next Post
fednow homepage displayed on mobile device

How Companies Can Get Ahead Using FedNow

No Result
View All Result

Privacy Policy | AI Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Research
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2025 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT
No Result
View All Result
  • Home
  • About
    • About CCI
    • CCI Magazine
    • Writing for CCI
    • Career Connection
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Library
    • Download Whitepapers & Reports
    • Download eBooks
    • New: Living Your Best Compliance Life by Mary Shirley
    • New: Ethics and Compliance for Humans by Adam Balfour
    • 2021: Raise Your Game, Not Your Voice by Lentini-Walker & Tschida
    • CCI Press & Compliance Bookshelf
  • Podcasts
    • Great Women in Compliance
    • Unless: The Podcast (Hemma Lomax)
  • Research
  • Webinars
  • Events
  • Subscribe

© 2025 Corporate Compliance Insights