Brendan Cullen, Partner in S&C’s Litigation Group, and Tony Lewis, Co-Head of S&C’s National Security Group, authored a chapter for Latin Lawyer’s Guide to Corporate Compliance, Sixth Edition, covering changes to enforcement priorities, investigative approaches and prosecutorial discretion in Latin America, as evidenced by U.S. government-issued directives. The authors provide guidance for multinational companies on how to develop robust compliance programs that meet the laws of multiple jurisdictions.
They also discuss the importance of maintaining effective compliance programs, which can mitigate the risk of consequences for a company later on. “It can prevent illicit conduct in the first place, it can detect it at the earliest possible stage if it does arise, and it can lessen or avoid many of the consequences that come with an enforcement action – not least of which could be a compliance monitor to help devise and implement a programme that should have been established in the first place,” they write.
Read the chapter.