Hospitality Risks At The 2016 Rio Olympics

We Brazilians are excited that the Summer Olympic games will be held in Rio de Janeiro in August 2016. We also know that the games will bring with them certain corruption risks under laws like the FCPA and the Brazilian Clean Companies Act (BCCA). Most prominent will be risks related to hospitality expenditures.

In particular, the SEC sent a strong warning on May 20, 2015, when it imposed a civil fine of $25 million on the Australian global resources company BHP Billiton ("BHP") to resolve charges of FCPA books and records violations. According to the SEC, BHP violated the FCPA's books and records provisions when it sponsored 60 government officials and their relatives at the 2008 Summer Olympic Games in Beijing. The SEC stated that BHP's guests, mostly from countries in Africa and Asia, were provided with three- and four-day hospitality packages that included event tickets, luxury hotel accommodations, and sightseeing excursions of between $12,000 to $16,000 each.