Six Compliance Lessons from the 2012 Latin America Corruption Survey

A recent survey of companies spanning 14 countries throughout the Americas, organized by U.S. law firms Miller & Chevalier Chartered and Matteson Ellis Law PLLC along with 12 Latin American law firms, provides insight into corruption issues in the region.  Four hundred and thirty nine respondents from local, regional and multinational companies completed the 2012 Latin America Corruption Survey.  The results offer perspectives on the extent of corruption in Latin American countries, the effects of corruption on companies operating in those countries, the effectiveness of regional anti-corruption laws, and tools that companies are using to address corruption risks.  For a summary of the survey, see “Miller & Chevalier and Matteson Ellis Law’s 2012 Latin American Corruption Survey Results Shows Increasing Awareness of the FCPA (Jul. 11, 2012).  In a guest article, James Tillen and Matteson Ellis provide additional analysis that will be useful to compliance personnel when they are evaluating the effectiveness of their compliance programs in Latin America.  In particular, Tillen and Ellis highlight four themes of the results and six corresponding takeaways from the survey findings for compliance officers.  Tillen is Coordinator of Miller & Chevalier’s FCPA and Anti-Corruption Practice Group, and Ellis is Principal of Matteson Ellis Law and writes the FCPAméricas Blog.

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