A Comparative Look at Anti-Corruption Compliance Program Expectations in Latin America

Anti-Corruption Report

10.28.2020

In this article, James Tillen, Alejandra Montenegro Almonte, and Abi Hollinger* use the framework of the DOJ and SEC's "Hallmarks of Effective Compliance Programs" to compare compliance program expectations of the U.S. with counties in the Latin American region, focusing on Argentina, Brazil, Chile, Colombia, Costa Rica, Mexico, and Peru. The authors wrote that "[c]ompanies seeking to maintain an anti-corruption compliance program that satisfies expectations of governments across the region and the United States need to understand the areas of overlap and divergence as well as how other companies in the region have implemented their programs." They note that "the United States has traditionally set the standards in anti-corruption compliance, local laws, in some instances go beyond the DOJ and SEC hallmarks," adding that companies need to "closely evaluate anti-corruption laws in all jurisdictions in which they operate to ensure that their programs align to the highest applicable compliance standard."

*Summer associate