Firms To Watch: Compliance

Estudio Olaechea focuses on compliance advisory and the designing of risk prevention strategies with recent mandates involving the review of contracts, running anti-corruption training sessions and implementing policies to abide by Peruvian regulations on anti-money laundering and prevention of terrorism financing; practice head Diego Abeo is the key contact.

Compliance in Peru

Payet, Rey, Cauvi, Pérez Abogados

Highly active in the market, Payet, Rey, Cauvi, Pérez Abogados’s compliance team acts for domestic and international clients on crime prevention, criminal investigations and the implementation of compliance controls. Under the leadership of Carlos Patrón, José Cúneo and Juan Diego Ugaz, the practice continues to assist clients with issues related to anti-money laundering, antitrust, financial matters, employment, health and safety, and environmental risk. Patrón is recommended for the implementation of antitrust compliance programs mandated by the National Institute for the Defence of Competition and the Protection of Intellectual Property (INDECOPI); and Ugaz is a name to note for criminal law, alongside Francisco Ugaz, who was promoted to the partnership in December 2021 and acts for clients in the infrastructure, financial, and oil-and-gas sectors. Principal associate Giancarlo Baella is recommended for competition, administrative and commercial law, and associate Erick Palao is another name to note. Since research concluded the firm has announced the hire of Ivan Meini (effective, September 2022); a renowned academic who also has a lengthy public-sector curriculum; he handles both white-collar and compliance matters.

Practice head(s):

Juan Diego Ugaz; Carlos Patrón; José Cúneo

Testimonials

‘Personalised advice is tailored to the specific needs of the client’.

‘They are quite flexible’.

‘They have managed to understand the core of our unusual business’.

Key clients

Graña y Montero Group (AENZA)

Work highlights

  • Advised Graña y Montero on a range of antitrust contingencies that could have affected the company.

Rebaza, Alcázar & De Las Casas

Rebaza, Alcázar & De Las Casas is recognised in the market for its broad compliance expertise, which encompasses the construction of tailor-made compliance programs, white-collar crime prevention and investigations, and internal investigations. The team can draw on multidisciplinary experience from its finance, data protection, employment, corporate and tax specialists, utilising their expertise to implement compliance programs, conduct fraud investigations and for training purposes. The team is jointly led by Augusto Loli and Héctor Gadea; with Loli recommended for the defence of high-profile criminal cases and litigation (with a particular focus on the public, financial, telecoms and infrastructure sectors); and Gadea handling internal investigations and fraud matters, often acting alongside large international law firms. At the senior associate level, Sergio Mattos brings international experience in money laundering and corruption cases, while Camilo Clavijo is a name to note for criminal litigation.

Practice head(s):

Augusto Loli; Hector Gadea

Key clients

Norvial

Sigma

Costeño Alimentos

Edpyme Acceso Crediticio

Crosland Automotriz (Crosland Group)

Chr Hansen

Universidad de Piura

Work highlights

  • Advised Universidad de Piura (UDEP) on developing a tailor-made compliance program/crime prevention system that meets the requirements established by Law No 30424 and its regulation.
  • Advised investment fund administrator Sigma on developing and implementing a tailor-made compliance program/crime prevention system.
  • Assisted Costeño Alimentos on the design of a tailor-made compliance program/crime prevention system that meets the requirements established by Law No 30424 and its regulation.

Rodrigo, Elías & Medrano – Abogados

The compliance practice at Rodrigo, Elías & Medrano – Abogados acts for a roster of high-profile domestic and international companies on the implementation of compliance programs and criminal investigations. The multidisciplinary team encompasses specialists in economic law, anti-bribery and anti-money laundering matters, employment, data protection and corporate issues; it advises clients on international regulatory issues, internal investigations, foreign corrupt practices act (FCPA) due diligence and M&A operations. The team is led by finance expert Fernando Molina, and José Reaño Peschiera, who is focused on business crime matters, including white-collar crime, tax evasion and financial fraud. Formerly at the High-Level Anti-corruption Commission (“CAN-Anticorrupción”), a state-entity, senior associate José Medina is the name to note for anti-corruption work, and handles the legal defence of criminal proceedings. Efraín Vassallo retired.

Practice head(s):

José Reaño; Fernando Molina

Testimonials

‘Mastery and knowledge on the subject is outstanding’.

‘Very solid team’.

‘Professionals who inspire a lot of confidence’.

‘The team has talent and integrity’.

Key clients

Telefónica del Perú

Belmond Peru Hotels

Scotiabank Peru

BBVA Banco Continental

Compañia Minera Antamina

Southern Peru Cooper Corporation

Pluspetrol Peru Corporation

Iridium Concesiones de Infraestructuras

Alicorp

Pan American Silver Peru

Intersur Concesiones

CMS Grau

CMS Grau fields a highly specialised team, which draws on expertise from its criminal, corporate and white-collar specialists to handle crime prevention, compliance and risk management. Key areas of focus include anti-money laundering, anti-corruption and fraud, as well as the design and implementation of compliance programs. As a large international firm, it is well placed to handle cross-border matters for both domestic and global clients. The team is led by Carolina Cueva , who has a wealth of experience in litigation and corporate and white-collar crime matters; she acts for private and public entities in the mining, oil and gas, insurance, banking and real state sectors, among others. Associate Tatiana Helguero  is also active in this area and is a name to note for compliance audits and anti-bribery work.

Practice head(s):

Carolina Cueva

Key clients

Corporación Breca

Marcobre

Corporación Peruana de Productos Químicos

Enagás Perú

Ferrovial Agroman Sucursal del Perú

Solvi Essencis Ambiental

Indeco

Consorcio Internacional Wayra

Limautos Automotriz del Perú

Gold Fields La Cima

Cementos Pacasmayo

Scania del Perú

Pan American Silver

Inmobiliaria Miraflores Perú

Cruz del Sur

Hudbay Peru

Work highlights

  • Acting for Corporación Breca on the simultaneous auditing of nine different business lines, resulting in more than 70 audited areas and more than 90 hours of interviews.
  • Advising Minsur’s compliance officer on a day-to-day basis on all matters relating to compliance.
  • Advising PanAmerican’s compliance officer on a day-to-day basis on all matters relating to compliance.

Estudio Echecopar member firm of Baker McKenzie International

Estudio Echecopar member firm of Baker McKenzie International’s compliance offering is led by Teresa Tovar, an experienced practitioner well regarded by clients. The team handles a broad range of preventative measures including anti-corruption and anti-money laundering, risk assessments and procedures to mitigate exposure to compliance violations. It is also well versed in the development of compliance programs, familiar with both domestic and international regulations (including FCPA and UK Bribery act matters), and has notable experience in internal investigations. The practice can cater to large international clients with ease by virtue of its large global network. Principal associate Viviana Chávez is the key figure for competition and data protection matters.

Practice head(s):

Teresa Tovar

Key clients

Telefónica del Peru

Derco Perú

Marcobre

Alicorp

Apoyo Consultoría

Minera Aurífera Retamas

IBT (Peru branch)

Komatsu Mining

Gedeon Richter

Samsung

Caterpillar International Services del Perú

C2 Mining Solutions (Logicalis)

Ocho Sur P S.A.C.

Telefónica Global Solutions Perú S.A.C.

Wayra Perú Aceleradora de Proyectos S.A.C.

Work highlights

  • Handling the design and implementation of compliance programs for C2 Mining Solutions, Altra Investments’ Transportes Acoinsa, and British American Tobacco, among others.
  • Conducting risk assessment processes and preparing risk matrices for Telefónica Global Solutions Perú, Wayra Perú Aceleradora de Proyectos, Media Networks Latin America, Telefonica Learning Services Peru, Derco Perú and Dercocenter, and Apoyo Consultoría.
  • Advised Minera Aurífera Retamas on the implementation of the recommendations and requirements made by the Financial Intelligence Unit of Peru (UIF Peru).

Miranda & Amado

Miranda & Amado handles the full gamut of compliance work, including anti-corruption, antitrust matters and corporate compliance issues. It has considerable experience in the design and implementation of compliance strategies, and has the capability to handle corporate crime matters, including internal investigations. Bruno Amiel heads the team with a focus on corporate compliance and ancillary expertise in project finance and dispute resolution, while Enrique Felices is the name to note for competition matters; he leads on several compliance cases. Following their January 2021 arrival from boutique Facto Litigios & Compliance (where they were founding partners) criminal liability specialists José Luis Velarde and Rafael Díaz were raised to the partnership at he beginning of 2022, further consolidating what is now a 15-strong practice group in this area. Public law specialist Willy Pedreschi; competition and administrative law focused Fiorella Zumaeta (also raised to the partnership in January 2022) and new counsel, Katherine Torres (a corporate expert who works closely with Amiel), are also all involved in the practice.

Practice head(s):

Bruno Amiel

Key clients

Statkraft

Talma Servicios Aeroportuarios

Aeropuertos del Peru

Arte Express

Inmobiliaria Koricancha

Marubeni

Grupo Repsol

DiDi Mobility Information Technology

Telefónica del Perú

Natura Cosméticos

Procesos de Medios de Pago

Amazon Web Services

United Heath Group (UHG)

Work highlights

  • Representing Repsol in four cases involving the investigation of price-fixing practices in the fuels market (ie: liquefied petroleum gas and natural gas) at a national and regional level before INDECOPI.
  • Advising DiDi Mobility Information Technology on all its competition and consumer protection matters.
  • Advising Telefónica del Peru on the identification of regulatory risks in telecommunications and competition matters, in order to design a plan to adapt its policies to current regulations and possible regulatory initiatives.

Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados

Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados caters to a roster of international conglomerates, as well as smaller domestic companies and trade associations, regarding the development of compliance programmes and risk management strategies. It is particularly experienced in compliance-related competition, consumer protection and personal data privacy protection matters. The team is jointly lead by Mauricio Olaya, Pierino Stucchi and Ian Paul Galarza, with José Antonio Bezada and senior associate Marco Antonio Ruiz Martinez also active in the practice. Olaya has considerable experience in the implementation of compliance models, while Stucchi, an INDECOPI alumnus, is a name to note for competition and risk prevention matters. Galarza brings white-collar crime expertise to the department and handles anti-money laundering issues and the prevention of terrorist financing.

Practice head(s):

Mauricio Olaya; Pierino Stucchi; Ian Paul Galarza

Key clients

Teva Pharmaceutical

Valero Energy Corporation

Hewlett Packard

EXSA (Orica Group)

B Braun Medical

Honda

Abbott

G W Yichang & Cia

Nestle

Redondos

COSAPI

Compañia Operadora de Gas

Flesan (DVC Infraestructuras)

Rimac Seguros y Reaseguros

Banco GNB

Scotiabank

Representaciones Martin

Coca Cola Servicios del Perú

Corporación Lindley

Laive

Work highlights

  • Developed a compliance program on antitrust regulations for Grupo Santa Elena which includes a risk-detection report and the development of internal preventive and mitigation protocols.
  • Developed a compliance program concerning data protection for CYPC China Yangtze Power Corporation that allows the proper relationship and exchange of data between the company (as controller) and Luz del Sur.
  • Developed a criminal risk assessment for Pluspetrol to manage criminal risks from the operation of a port terminal located in Pisco.

Benites, Vargas & Ugaz

Practice co-head and counsel Liliana Calderón, who is highlighted by clients for her ‘dedication and knowledge‘, leads on the majority of Benites, Vargas & Ugaz‘s compliance matters, frequently assisted by associate Jesús Cornejo. The team advises subsidiaries of business conglomerate Grupo Breca, including Administradora de Empresas and Minsur, as well as counting Telefónica del Perú as a client, for which the practice group carries out risk assessments. The team also updated a compliance programme for Linea 2 Metro de Lima, as well as designing new programmes for non-profit organisations and auditing compliance programmes for insurance companies. Practice co-head Roberto Pereira advises on compliance with anti-money laundering regulations. Since research concluded, and in a major boost to the practice, the firm has hired Juan F Jiménez Mayor as a counsel; a former minister of Justice & Human Rights, Jiménez has specialisations in compliance, constitutional law and penal norms and procedural law – effective as of October 2022.

Practice head(s):

Roberto Pereira; Liliana Calderón

Testimonials

‘The team has specialists who – for my sector of non-profit civil associations linked to research and development of public policies – are not common in the law firm market.

‘They understand our activities and processes in detail‘.

‘The specialist responsible for our project – Liliana Calderón – perfectly understood the needs of our sector, accompanied the process constantly and patiently, in addition, she was very specific and detailed in the products, processes and policies that we had to adopt as an association‘.

‘The area has a solid team of lawyers specialised in the matter, which provides a quality service with a friendly and collaborative approach‘.

‘Communication is permanent, fluid and they are punctual in the delivery of documents‘.

‘They are lawyers who have a good training in corporate criminal law and solid studies in regulatory compliance‘.

‘The compliance practice of the Benites, Vargas & Ugaz Abogados law firm, led by Liliana Calderón, brings together excellence in service, careful customer service and outstanding experience‘.

‘The compliance team is characterised by being a very cohesive group, dynamic and always attentive to changes‘.

Key clients

Tecnológica de Alimentos (Tasa)

Minsur

Rimac Seguros

Telefónica de Perú

Obrascon Huarte Lain (Peru branch)

Metro de Lima Línea 2

Grupo Inmobiliario Capac

ODP Jesuitas del Perú

Hidrandina

AESA

Asociación de Contribuyentes del Perú

Pluspetrol

Sergemi Contratistas

Work highlights

  • Updating and strengthening of Línea 2 del Metro de Lima’s compliance programme to current legislation and the highest international standards.
  • Advising Minsur on several internal investigations regarding complaints in different matters presented through a whistleblower channel.
  • Conducted a risk assessment process regarding tax and customs matters for Telefónica del Perú, in order to prevent the legal risk associated with them.

Caro & Asociados

Led by ‘brilliant lawyerDino Carlos Caro Coria, Caro & Asociados undertakes investigations and compliance advice for clients. Its work predominately involves training on compliance with regulatory requirements, as well as internal investigations, criminal risk mitigation, compliance programme development, external audits and advice on obtaining official certifications. Luis Miguel Reyna Alfaro, who has experience in anti-bribery compliance, and normative compliance consultant Virginia del Pilar Naval Linares, co-lead the practice and assist Caro with key matters, supported by dispute resolution head María Alejandra Quintana Gallardo.

Practice head(s):

Dino Carlos Caro; Luis Miguel Reyna; María Alejandra Quintana; Virginia del Pilar Naval

Testimonials

‘The attention is personalised and there is a follow-up of the service, the communication is easy and the answers are immediate‘.

‘It is a fairly specialised firm in compliance and criminal law issues, so it differs precisely in these specialities‘.

‘Carlos Caro is a lawyer who not only leads the firm but also has a great facility for communication and for transferring his knowledge through training and teaching in general‘.

‘Carlos Caro has extensive experience and knowledge in matters of compliance, criminal law, economic and related issues such as anti-corruption prevention models and anti-money laundering, among others‘.

‘Carlos Caro is always willing to help and give additional insight to the issues‘.

‘Carlos Caro is a brilliant lawyer; he is one of the best and leading lawyers in Peru‘.

‘Carlos Caro has a great command of criminal theory, but he also knows the “field”, that is, he has a lot of experience and knowledge of the Peruvian criminal reality‘.

Cortez Massa & Bello Abogados

Closely focused on penal litigation, criminal compliance and related advisory matters, Cortez Massa & Bello Abogados is a small but highly specialised boutique that advises a number of sizeable clients, along with SMEs) on criminal-compliance programmes, as well as handling compliance breaches and trials involving public administration, money laundering, cartel activity, and environmental and taxation matters, among others. The firm's three name partners, Luis Felipe Cortez, Jorge Massa and Christian Bello are all expert criminal litigators with around 20 years' experience each. The practice continues to enjoy a growing client roster, particularly in relation to the mining sector; however, former associate Paul Mendoza moved in house at Minera Aurífera Retamas as of July 2022.

Practice head(s):

Jorge Massa; Luis Felipe Cortez; Christian Bello

CPB Abogados

CPB Abogados compliance offering was notably augmented with the August 2021 arrival of Pia Iparraguirre as a senior associate; she now co-leads the practice with managing partner Germán Carrera and key partner Mario Pinatte, who also heads up the firm’s conflict resolution and crisis management practice. The group undertakes the development of policies, controls and compliance programs; handles risk detection, analysis, and management, along with the preparation and adaptation of manuals, ethics codes and other documents; and conducts training programs on compliance, good corporate governance and risk management, among other matters. It also undertakes criminal due diligence, involving the investigation and follow-up of all the police, fiscal and judicial records of criminal matters to detect the level of criminal risk in money laundering and financing of terrorism. In addition to her experience of criminal law, criminal procedure, compliance and risk management systems, Iparraguirre – who arrived from the Peruvian Ministry of Justice and Human Rights where she was a senior advisor – is also knowledgeable regarding environmental matters, having previously worked at regulator OEFA.

Practice head(s):

German Carrera; Mario Pinatte; Pía Iparraguirre

Key clients

Inmobiliaria De Turismo

Empresa de Administración de Infraestructura Eléctrica

Grupo Inmobiliario Aurora

Ibañez Solano (Peru branch)

Mambrino

Gerpal

Flat Arequipa

Pronokal Peru

Urbi Proyectos

Dresden Corp

Yamaha Motor Del Perú

Cartavio Rum Company

Tiendas por Departamento Ripley

Banco Ripley Perú

Work highlights

  • Undertook the implementation of criminal compliance programs and anti money laundering and financing of terrorism system according to Peruvian law and international guidelines on behalf of Empresa de Administración de Infraestructura Eléctrica.
  • Permanent legal advice and support on criminal compliance matters to both Banco Ripley and Tiendas por Departamento Ripley in all of their Peruvian premises and on a day-to-day operational basis.
  • Legal advisory to Grupo Inmobiliario Aurora regarding the implementation of GDPR, including advice on the preparation and registration of personal data with the Ministry of Justice.

DS Casahierro Abogados

Part of the France-headquartered DS Avocats international network, DS Casahierro Abogados often advises the Peruvian branches of international parent companies as well as advising the parent companies themselves. Led by José Matto, who is closely supported by ‘meticulous and knowledgeable’ senior associate Emma Canchari, the team undertakes the development of both anti-bribery and money laundering prevention systems, implements anti-corruption controls in compliance software, advises on ISO standards, reviews current compliance programmes, and provides support with the designation of new compliance officers and analyses contracts. The team works with a range of industries but is particularly active in the construction sector.

Practice head(s):

José Matto

Testimonials

‘I recognise the disposition, adaptability and team leadership, personalising the scope of the services to our needs‘.

‘We decided to work with DS Casahierro due to their availability and flexibility in different aspects, but always maintaining a high degree of knowledge of the issues entrusted to them‘.

‘José Matto is a partner who is always available to solve problems that arise and has been able to select his team appropriately, such as Emma Canchari, who is a high-level specialist for regulatory compliance issues. They always seek to provide solutions in a flexible manner and adapting to the circumstances‘.

‘It has a young but solid team with knowledge in compliance, they advise comprehensively with the core business. They are collaborative and adapt to change‘.

‘Emma Canchari is outstanding, goes hand in hand with the partner, very meticulous and knowledgeable about national regulations‘.

‘High technical and professional capacity of the team. Cordial treatment and mainly dedication and focus on the client. Order and transparency‘.

‘What stands out in the team is its technical and professional capacity and the work they carry out is individualised. The concern for the client is evident and they are always willing to change to accommodate the needs that the client raises‘.

Key clients

Komatsu-Mitsui Maquinarias Perú

Enotria

Primus Capital Perú

Primus Capital Créditos

Sacyr Construcción Perú

Sacyr Operación y Servicios Perú

Productos Roche QF

Compañia Nacional de Chocolates

Terpel Comercial del Perú

Terpel Perú S.A.C.

América Móvil Perú (Claro Perú)

Medinet

Primus Capital Leasing

Mareauto Perú (Avis)

Mareauto Perú

Volvo Perú

Sacyr Industrial Perú

GCZ Ingenieros

Futuro Invest

Sociedad Nacional de Pesquería (SNP)

Autopista del Norte

Consorcio Inti Punku

Cumbra Perú

Terpel Aviación del Perú

Grifosa

Comité Nacional de Administración del Fondo para la Construcción de Viviendas y Centros Recreacionales para los Trabajadores en Construcción Civil del Perú (CONAFOVICER)

AGP Perú

GMVBS (Empresa de Cumbra)

Arteco Inmobiliaria

Concar Perú

Electro Ucayali

Telefónica Cyberscurity Tech Perú

Work highlights

  • Implemented the ISO 37001 standard for América Móvil Perú, which will allow the company to be the first one in the telecommunications sector with qualified controls against corruption and an ISO 37001 certification, as well as obtaining a higher score in public tenders.
  • Provided legal support undertaking the adaptation of the ISO 37001 standard for Sacyr Construcción Perú / Sacyr operación y Servicios Perú, which allows the company to access the standard certification, with the benefit of earning additional points in public contract contests.
  • Assisted jint venture Inti Punku with the implementation of a compliance programme within the framework of its operations in the runway expansion of the Jorge Chávez International Airport.

Hernández & Cía

Hernández & Cía's practice co-head Gonzalo del Río has been handling the long-running defence of Aenza (formerly Graña y Montero), regarding investigations and criminal proceedings brought against its former directors in relation to the Lava Jato scandal. In recent years the team designed a compliance programme for Aenza to abide by both Peruvian and international standards, as well as carrying out an internal investigation for the client. Current work includes analysing the SPLAFT system (regarding anti-money laundering and countering of terrorism financing) and providing recommendations for compliance to non-profit and security clients. The team also develops compliance programmes for universities, a maritime and aircraft operator and real estate clients, among others. Co-head Alfredo Filomeno provides experience regarding corporate structures, and senior associate Kris Maquin regularly provides support on relevant mandates.

Practice head(s):

Gonzalo del Río; Alfredo Filomeno

Testimonials

‘It is a solid interdisciplinary team with extensive knowledge of good practices and the regulations applicable to business in Peru’.

‘Closeness to the client and high level of service and attention to detail’.

Key clients

Graña y Montero (now Aenza)

Universidad San Ignacio de Loyola

IPAE

Liderman

Hermes

HudBay

Puma

Unimar Logistica

Inmobiliaria Marítima (INMAR)

Work highlights

  • Advised Aenza (former Graña y Montero) on corporate crisis management.
  • Conducted an independent investigation for Aenza (Graña y Montero) in order to collaborate with the authorities in the Lava Jato case.