Alejandra Montenegro Almonte Quoted on Potential Corporate Compliance Risks Resulting from Engel List in International

"Lawyers Warn Clients to Tighten Compliance in Central America" International


International Member and Vice Chair Alejandra Montenegro Almonte commented on the Engel list – the U.S. government's list of allegedly corrupt officials from Guatemala, Honduras, and El Salvador, known as the Northern Triangle. She said in-house counsel and compliance officers at companies with business dealings in those countries should review potential points of contact between their entities and the named individuals. "Companies would be safe to assume that the individuals named on the Engel list are or soon will be under investigation by U.S. and foreign authorities," Montenegro Almonte noted via email. A company operating in any of those countries, she added, would be well-served to identify beneficial agency rulings or legislative efforts in the region that may have been obtained over the last five years – and to determine whether those gains involved ministers or legislators on the Engel list. In the event a company detects a connection with a named individual, Montenegro Almonte suggests they launch an internal investigation as well as a focused forensic review of the company's books and records and a testing of its internal controls.