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ARTICLE · 04 OCTOBER 2022

FCPA Developments In Latin America

Womble Bond Dickinson
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The prosecution of the insurance bribery scheme shows the far reach of FCPA jurisdiction.

United StatesCriminal Law
Luke Cass
Luke Cass
William D. Curtis
William D. Curtis
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In June of 2021, the Biden Administration announced that combating corruption in Latin America was an economic and national security priority, pledging to coordinate resources to fight corruption, curb illicit finance, and build international partnerships in the anti-corruption fight while improving foreign assistance.

Numerous recent enforcement actions including Glencore, Stericycle and Tenaris involving activity across the continent have demonstrated the Biden Administration's resolve on anti-corruption efforts in Latin America, not least of which is the recent return of forfeited criminal proceeds to Peru as part of the ongoing Odebrecht bribery case. In addition to corporate actions, the DOJ commitment to aggressively pursue individual prosecutions within the alleged bribery schemes continue to show.

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