What In-House Counsel Need to Know Regarding Compliance and Enforcement of U.S. Anti-Corruption Laws: Recent Cases Focus on Latin America

August 23, 2012

BY THOMAS P. O'BRIEN, DANIEL PRINCE, & JOHN O'KANE, IV

The United States Securities and Exchange Commission (the SEC) and Department of Justice (the DOJ) have devoted significant resources to the enforcement of anti-corruption laws; however, in many cases, the governments scrutiny has not been limited to the payment of bribes to foreign officials. Rather, in its investigations, the government also has considered (and likely will continue to consider) a corporations culture of compliance, such as the efforts of compliance personnel and in-house counsel (and, in some cases, upper management) to identify and remedy the alleged wrongdoing as opposed to attempting to cover it up".

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