FCPA Compliance Report

The Miller & Chevalier 2020 Latin American Corruption Survey-Part 4, Compliance Program Design and Implementation


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Welcome to a special five-part podcast series where I take a deep dive into the Miller & Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyers James Tillen, Matt Ellis, Alexandra Almonte and Greg Bates. Miller & Chevalier and 14 partner firms have tracked perspectives on anti-corruption issues in the region since 2008. It is the most comprehensive survey on the perception of corruption in Latin America. 

This year, 54 percent of survey respondents said corruption is a significant obstacle to doing business – up 10 percent since 2012 – while only 45 percent of respondents believe offenders are likely to be prosecuted, down from 66 percent in 2008. Despite Latin America's anti-corruption progress over the last decade this new survey data reveals corruption risk to be at an all-time high across the region.

In this Episode 4, I visit with firm Counsel Greg Bates and we explore some of the Survey’s data on compliance program design and implementation. Some of the highlights include:

  • What does the Survey data mean for in-house compliance officers?
  • What trends does the Survey indicate vis-à-vis compliance program data?
  • The Survey had almost 1000 respondents, with a mix of representatives from multinational, local/regional, and public and private companies. Do you see different levels of importance of ABAC compliance programming based on the type of company that responded?  
  • What other efforts to manage bribery and corruption risks are you seeing in the Survey data?  
  • The Survey was conducted just before Coronavirus hit Latin America. Looking into your crystal ball, how do you think COVID-19 will impact compliance programming in the region?
  • Join us in our final episode where I am joined by James Tillen and Matt Ellis to take a retrospective look back over the 12 years of Miller & Chevalier’s Latin American Corruption Survey.

    For more information on the Miller & Chevalier Chartered 2020 Latin American Corruption Survey, click here. The Survey is available in English, Spanish and Portuguese. 

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