Latin America

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.

The new Law on Corporate Criminal Liability for corruption offences is approved and now companies should take the appropriate measures in order to prevent and detect possible corruption crimes committed in their workplace.

On September 27, 2017, the Mexican Senate passed a bill that amended Mexico's main environmental law. One of the most relevant amendments deals with fines for environmental violations which will increase if the bill passes.

Our survey analyzed where commercial bribery is a criminal offense, who may be prosecuted and how active the local authorities are.