Anti-Corruption Compliance and FCPA Enforcement in Latin America

    View Author 12 March 2021
    In an article for The Review of Securities & Commodities Regulation, of counsel Jose Martin addresses the SEC’s enforcement action against WAC for largescale bribery in its Mexican subsidiary, finding the case of particular interest because the business model itself was high risk, red flags were ignored, and union and government officials were joined in the misconduct. Martin also highlights the new requirements in Latin America for companies to have compliance programs and, as part of such programs, to conduct third-party due diligence.