Shooting For Effective Anti-Corruption Compliance: A Look At Recent Developments In Brazil

A recently disclosed bribery scandal related to the 2014 FIFA World Cup in Brazil, along with other anti-corruption developments in Brazil, has reinforced the importance of implementing effective compliance policies and procedures. On March 22, 2015, Bilfinger released a statement that it was conducting an internal investigation into allegations that employees of Mauell, its Brazilian subsidiary, paid bribes to public officials and employees of state companies in Brazil. Mauell supplied monitor walls and software for security control centers, which oversaw the flow of traffic at the World Cup. In total, the orders were worth approximately $6.5 million. In its statement, Bilfinger confirmed that the suspicions were substantiated. Bilfinger had previously entered into a deferred prosecution agreement with the U.S. Department of Justice on December 9, 2013, and paid a $32 million penalty relating to allegations that it had bribed Nigerian government officials to obtain and