On 30 April, Latin Lawyer published an article (a chapter from the “Guide to corporate compliance in US & Latin America”, published in June by the Latin American Corporate Counsel Association) which traces how compliance programmes have evolved from being considered a luxury to becoming a necessity, especially for leniency in corporate prosecutions. It says that, until the beginning of 2010s, compliance was merely a secondary concern for companies in Latin America, seen as a superfluous investment with uncertain incomes. Even for companies subject to international anti-corruption laws, such as the FCPA and UK Bribery Act, compliance was often in place just as a paper programme without sufficient human and financial resources. However, it said that this situation began to change at the end of 2014 with the launch of Operation Car Wash. The article concludes that, in the US and Latin America, compliance began with a focus on rules-based systems and employee training. Over time, government agencies have required, and corporations have realised, that compliance programmes serve as proactive measures to detect and prevent corruption. Compliance is no longer about simply following the letter of the law. Compliance is, it says, now evolving beyond simple legal compliance to a consideration of societal benefits and a holistic approach.




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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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