Matteson Ellis was quoted regarding Transparency International's annual Corruption Perception Index. "Corruption risks in Venezuela continue to get dramatically worse, given the security situation, the state of the economy and general disorder," Ellis said. It has become difficult for local companies to perform basic compliance tasks and for parent companies to exercise proper compliance oversight of their local subsidiaries in Venezuela, which has an effect on FCPA risk. "Many qualified compliance professionals have left the country, it can be complicated to conduct internal investigation interviews when people are afraid to talk about bribery schemes, and compliance training is not as easy to conduct when employees are reluctant to fully engage," he added.

Ellis discussed other parts of Latin America as well. According to Ellis, there are some common, very visible risks in Central America. "The countries' governments and business communities are usually controlled by a small community of powerful elites, and as the people who serve as leaders in government are often related to those who serve as leaders in business, Central American countries can be seen as very insular and particularly risky," he said. With respect to the other end of the spectrum, Chile and Uruguay were listed as the least corrupt countries in the region. "Companies do not confront the same levels of corruption risk when operating in Chile as they do in other Latin American countries -- they confront rules that are much more reliable and consistently applied. It is less common to hear of Chilean officials requesting bribes from businesspeople. However, Chile still has had its own important domestic bribery cases, demonstrating that risk still exists," Ellis said.