P13: Enforcement Goes International-What Does it Mean for Your Compliance Program?


Multinational/ International


Thomas R. Fox, Compliance Evangelist, Advanced Compliance Solutions

Matt Ellis, Partner, Miller

Carlos Ayres, Partner, Maeda, Ayres e Sarubbi Advogados

  • Brazil now leads the list of countries where companies are under FCPA investigation. Yet that is often only the tip of the overall number of countries where companies may be under investigation.
  • From the US corporate compliance perspective, how can a company protect itself from an industry or country sweep? Why do you need to understand not only who your third parties and business partners are but your customers as well?
  • From the Brazilian perspective, what should companies be doing proactively in response to this or any other country sweep? How is this different from the American perspective? Is doing compliance in Brazil or any other country in South America different?

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