Miller & Chevalier, Matteson Ellis Law and 12 Latin American Firms Release Results of 2012 Latin America Corruption Survey

Some Improvements Seen Since 2008 Survey, but More Work Still Needed as 72% of Respondents Say Anti-Corruption Laws Are Ineffective in their Country

Washington, D.C., June 14, 2012 – Miller & Chevalier Chartered and Matteson Ellis Law PLLC today announced the results of their 2012 Latin America Corruption Survey gauging the understanding and effectiveness of anti-corruption laws that regulate the behavior of businesses in the region. While some of the survey results showed remarkable consistency with a similar study Miller & Chevalier conducted in 2008, there were notable differences suggesting a growing focus on the part of businesses on anti-corruption laws in the region, including more attention to compliance and more widespread familiarity with the Foreign Corrupt Practices Act (FCPA).

Corruption continues to make an economic impact in the region, and half of all 2012 survey respondents say that their company has lost business to competitors making illicit payments in the region. Further, 44 percent of executives surveyed say corruption is a significant obstacle to doing business. Just 28 percent of respondents believe anti-corruption laws are effective in the country where they work.

However, the anti-corruption environment throughout the region is showing some signs of improvement. For example, 85 percent of respondents say their company’s management has taken steps to protect the organization from corruption risk, up from 77 percent in 2008. Three-quarters of respondents are aware of an offender being punished for making or receiving illicit payments, up from 69 percent in 2008. These slight changes, in the aggregate, suggest an overall movement toward improvement and potential trends to watch.

"At first glance, we don’t see a lot of change in the perception of widespread corruption throughout the Americas. However, a closer look at the individual results shows a distinct, while not dramatic, uptick in awareness and enforcement throughout the region. Companies understand the potentially high cost of corruption and are investing in education and other tools to protect their reputation, their employees, and their bottom line," said Miller & Chevalier FCPA & International Anti-Corruption Practice Group Coordinator James Tillen.

"We are beginning to see significant disparities between regional companies and multinational corporations when it comes to the implementation of anti-corruption protection measures. While multinationals have increased training, enacted new policies and added due diligence procedures over the past four years, regional businesses report making significantly fewer investments during that time period. Local companies do not yet view corruption risk as a top priority in the same numbers as multinational organizations," added Matt Ellis, Principal at Matteson Ellis Law. 

Survey Highlights

In late April and early May, Miller & Chevalier, Matteson Ellis Law and 12 Latin American partner firms spanning 14 countries distributed the survey via e-mail to corporate executives at a broad cross-section of U.S. and Latin America-based companies. The survey, available in English, Spanish and Portuguese, was completed by 439 respondents. Some survey highlights include: 

  • Chile (76%) and the United States (70%) are seen as having the most effective anti-corruption laws of the countries examined. Paraguay (0%) and Guatemala (2%) got the lowest marks for potency of anti-corruption legislation. 
  • More companies are prioritizing compliance. Among companies publicly listed in the United States and operating in Latin America, 92% have developed an anti-corruption policy, 90% have implemented anti-corruption training and 90% have established procedures for gifts, travel and entertainment for officials. 64% employ full-time compliance personnel. 
  • The most frequently implemented anti-corruption measures for multinational, regional, and local companies include anti-corruption policies (81%); procedures for gifts, travel and entertainment for officials (70%); procedures for charitable and community donations (63%); and anti-corruption training (61%). 
  • Effective government investigation and prosecution, coupled with enhanced accountability and transparency in the public sector, are seen as keys to reducing overall corruption. 
  • 64% of respondents say they are somewhat or very familiar with the FCPA. 41% say they are somewhat or very familiar with the UK Bribery Act (UKBA).

For a full copy of the survey results and analysis, please contact Laura Miller at (312) 252-4104 or  A report on the findings is also available at and

About Miller & Chevalier

Founded in 1920, Miller & Chevalier is a Washington, D.C. law firm with leading practices in tax; employee benefits, including ERISA; international law and business; white collar and internal investigations; complex litigation; and government affairs. Miller & Chevalier has more than 30 years of diverse experience advising clients on complex Foreign Corrupt Practices Act (FCPA) and other anti-corruption matters. For more information on the firm, visit

About Matteson Ellis Law

The FCPA compliance law firm Matteson Ellis Law, PLLC has in-depth experience including on-site investigations in over 20 high corruption risk countries throughout the Americas, Europe, Africa, and Asia. Matteson Ellis Law, PLLC helps companies build internal compliance programs, conduct due diligence on third parties, perform internal investigations, analyze transactions for compliance, and train employees. For more information on the firm, visit


James Tillen, Member, Miller & Chevalier FCPA Practice, 202-626-6068
Matt Ellis, Principal, Matteson Ellis Law, 855-327-2529
Laura Miller, Media Relations, Greentarget, 312-252-4104

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