Risky business

Miller & Chevalier members Brian Fleming and Alejandra Montenegro Almonte detail the growing US sanctions risk for Latin American companies.

Risky business Brian Fleming and Alejandra Montenegro Almonte

Throughout the Latin American and Caribbean compliance community, anti-­corruption risk associated with the US Foreign Corrupt Practices Act (FCPA) and the menacing possibility of an enforcement action by the US government is well known. The prospect of massive financial penalties and costly, time-­consuming investigations is often incentive enough for companies in the region to invest the time and resources to assess their FCPA-­related risk, and take appropriate compliance steps to mitigate it. This trend is only increasing – and we expect will continue to do so – as countries in the region adopt and enforce anti­corruption legislation of their own.



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