Latin America

Since 2 March 2018, corporate criminal liability law (Law 27,401) is in force. Legal entities will be subject to sanctions in these offenses against the Public Administration and/or corruption: (i) national and transnational bribery and influence peddling; (ii) improper and unlawful transactions of public officials; (iii) illegal exaction committed by a public official; (iv) illicit enrichment of public officials and employees; and (v) forgery of balance sheets and reports to conceal a corruption offense.

The new law determines the mandatory implementation of a compliance program for companies that enter into contract, partnerships, agreements, concessions, or public-private partnerships with the public administration of the Federal District

This issue of the Ethics & Compliance in the Americas newsletter covers what the DOJ considers as cooperation, as updated by the new FCPA Corporate Enforcement Policy.

Brazil introduced measures to facilitate the report of crimes and administrative offences.

This issue of the Ethics & Compliance in the Americas newsletter covers the new FCPA Corporate Enforcement Policy, which replaced the FCPA Pilot Program that had been in effect since April 2016.

The Brazilian Control Council for Financial Activities published a new resolution on Politically Exposed Persons which will expand the list of people defined as Politically Exposed Persons.

New legislation has been published according to which companies entering into contracts with the public administration of the state of Rio de Janeiro, directly or indirectly, will be mandated to implement an Integrity Program (or "compliance program").

Building on the success of 2016’s “EMEA Corporate Liability Handbook,” we are pleased to present you with the first global edition that collates and describes in detail the corporate liability and corporate crime regimes of countries in Asia, EMEA and the Americas.

On August 28, 2017, Petróleos Mexicanos published its new Code of Conduct. The Code outlines the corporate ethics principles and guidelines mandatory for all employees, subsidiaries and affiliates.

The EU imposed sanctions on Venezuela in response to the continuing crisis in Venezuela and the perceived deterioration of democracy, the rule of law and human rights.