Corporate Compliance Considerations Following the Publication of the Engel List

Corporate Compliance Insights

08.25.2021

In this article, Members Alejandra Montenegro Almonte and William Barry and Counsel Maria Lapetina offer practical insights into compliance considerations related to the recent publication of the Engel List and how the move signals a renewed focus by the U.S. Department of Justice in the Northern Triangle of Central America. On July 1, 2021, Secretary of State Antony Blinken issued a report listing 55 individuals suspected of corruption and antidemocratic conduct in Guatemala, El Salvador, and Honduras. A list of this sort invites scrutiny from regulators, counterparties, shareholders, and other stakeholders. It can also give rise to a number of compliance, regulatory, commercial, and reputational risks for business affiliated with these individuals. The authors assert that businesses and entities with potential affiliations to these individuals would be wise to assess the risks posed by these affiliations and consider taking active steps to mitigate those risks.