FCPA professor -chile

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Mike Koehler analiza requisitos y defensas de varios países de la OCDE, frente a la FCPA de USA. Chile en página 3.

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FCPA professor -chile

  1. 1. FCPA Professor: Chile Compartir Informar sobre mal uso Siguiente blog» Crear un blog Acceder FCPA Professor A Forum Devoted to the Foreign Corrupt Practices Act Meet the Professor Showing newest posts with label Chile. Show older posts View my complete profile TUESDAY, JUNE 28, 2011 The Compliance Defense Around The World Subject Matter Index As highlighted in this prior post, numerous FCPA reform bills in the 1980s included a specific defense which stated a company 2011 Enforcement Actions (12) would not be held vicariously liable for a violation of the FCPA’s ABB (2) anti-bribery provisions by its employees or agents, who were not Abu Dhabi (1) an officer or director, if the company established procedures reasonably designed to prevent and detect FCPA violations by Act of State Doctrine (1) employees and agents. An FCPA reform bill containing such a ADRs (1) provision did pass the U.S. House, but was not enacted into law. Affirmative Defense - Local Law (1) Amending the FCPA to include a compliance defense is one of Affirmative Defense - the U.S. Chambers FCPA reform proposals (see here). In Promotional Expenses (3) November 2010, Andrew Weissman, on behalf of the Chamber, testified in favor of a compliance defense (and other reform Afghanistan (1) proposals) during the Senates FCPA hearing (see here for the Africa Sting (23) prior post) and during the House hearing earlier this month (see AGCO Corporation (1) here for the prior post), former Attorney General Michael Mukasey, on behalf of the Chamber, also testified in favor of a Aguilars (1) compliance defense (and other reform proposals). Aid and Abet (2) Airbus (1) During the House hearing, there appeared to be bi-partisan Alba (1) support for consideration of an FCPA compliance defense. Albert Jack Stanley (2) Even so, Greg Andres, testifying on behalf of the DOJ, stated Alcatel-Lucent (5) that a potential FCPA compliance defense was "novel and risky" Alliance One International (7) and that the "time is not right to consider it." Allied Defense Group (1) Public debate on a potential compliance defense has thus far Allison Transmission (1) focused, from a comparative standpoint, on the United Kingdom ALSTOM (2) and Italy. Angela Aguilar (1) The purpose of this post is to further inform the public debate Angola (4) on a potential compliance defense by highlighting various Antonio Perez (1) compliance-like defenses around the world in other countries Anything of Value (4) that are signatories (like the U.S.) to the OECD Anti-Bribery Argentina (2)http://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  2. 2. FCPA Professor: Chile Convention. Armor Holdings Inc. (1) This post is further to my work in progress - Revisiting an FCPA Asset Recovery (9) Compliance Defense - and represents hours of research analyzing 38 OECD Country Reports. AstraZeneca (1) Australia (3) The post provides an overview of compliance-like defenses in Avery Dennison (1) the following OECD Convention signatory countries: Australia, Chile, Germany, Hungary, Italy, Japan, Korea, Poland, Portugal, Avon (5) Sweden, and Switzerland. [The U.K. Bribery Act, set to go live Azerbaijan (3) on July 1st, also contains a compliance-like defense in Section BAE (36) 7]. Bahrain (1) A first reaction might be - only 12 of the 38 OECD member Baker Hughes (2) countries have a compliance-like defense. Ball Corporation (2) Bangladesh (2) However, this number must be viewed against the backdrop of the following dynamics: (i) in many OECD Convention signatory BellSouth Corporation (1) countries, the concept of legal person criminal liability (as BHP Billiton (1) opposed to natural person criminal liability) is non-existent; and BJ Services (1) (ii) in many OECD Convention signatory countries that do have legal person criminal liability, such legal person liability can only Blackwater (1) result from the actions of high-level executive personnel or Bobby Benton (2) other so-called "controlling minds" of the legal person. Bobby Elkin (1) Bonny Island Bribery (8) Obviously if a foreign country does not provide for legal person liability, there is no need for a compliance defense, and the Books and Records (7) rationale for a compliance defense is less compelling if legal Bourke (10) exposure can result only from the conduct of high-level BP (2) executive personnel or other "controlling minds." Brazil (2) When properly viewed against these dynamics, a compliance- Cambodia (1) like defense (whether specifically part of a foreign countrys Canada (7) "FCPA-like" law or otherwise generally part of a foreign countrys legal principles) is far from a "novel" idea, but rather common Carson (8) among OECD Anti-Bribery Convention signatory countries that - CB Richard Ellis (1) like the U.S. - have legal person criminal liability that can Charitable Contributions (2) attach based on the conduct of non-executive officers or other Charles Paul Edward Jumet (6) "controlling minds." Chevron (2) [The below information is based strictly on OECD country Chile (1) reports and is subject to the qualification that in many China (27) instances the most recent information concerning a particular country may be several years old. If anyone has more recent Collateral Effects (10) information concerning any particular country, how the Colombia (1) compliance defense in a particular country has worked in Compliance (12) practice, or any other relevant information, please leave a comment on this site or contact me at mjkoehle@butler.edu] Compliance Defense (1) Comverse Technology (3) ***** Con-Way Inc. (1) Congo (2) Australiahttp://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  3. 3. FCPA Professor: Chile Congressional Activity (20) Australian law implementing the OECD Convention entered into Consultants (1) force on December 18, 1999. Consumer Products Industry (1) Thereafter, a section of the Criminal Code on corporate criminal Control Components Inc. (4) liability came into full force establishing an organizational Control Person (2) model for the liability of legal persons. “Bodies corporate” are Costa Rica (3) liable for offences committed by “an employee, agent or officer of a body corporate acting within the actual or apparent scope Craig Huff (1) of his or her employment, or within his or her actual or apparent Croatia (1) authority” where the body corporate “expressly, tacitly, or Cuba (1) impliedly authorised or permitted the commission of the Customer Rewards Programs offence”. (2) Pursuant to the Criminal Code, authorisation or permission by CustomsGate (8) the body corporate may be established in the following ways: (1) Daimler (12) the board of directors intentionally, knowingly or recklessly David Turner (1) carried out the conduct, or expressly, tacitly or impliedly authorised or permitted it to occur; (2) a high managerial agent Debarment (17) intentionally, knowingly or recklessly carried out the conduct, or Declination Decisions (2) expressly, tacitly or impliedly authorised or permitted it to Deferred Prosecution occur; (3) a corporate culture existed that directed, Agreements (31) encouraged, tolerated or led to the offence; or (4) the body Delta and Pine (1) corporate failed to create and maintain a corporate culture that required compliance with the relevant provision. DePuy (1) Deutsche Telekom (1) However, under the Criminal Code, “if a high managerial agent Diageo (1) is directly or indirectly involved in the conduct, no offence is committed where the body corporate proves that it “exercised Diebold (1) due diligence to prevent the conduct, or the authorisation or Digi International (1) permission." Disgorgement (2) Chile Dodd-Frank (1) DOJ (6) Chilean law implementing the OECD Convention entered into DOJ Enforcement Action (4) force on October 8, 2002. Double Standard (3) In December 2009, a separate Chilean law entered into force Douglas Faggioli (1) establishing criminal responsibility of legal persons for a limited Dubai (1) list of offences including bribery of foreign public officials. Due Diligence (6) In order for a legal person to be held responsible for a foreign Dyncorp (1) bribery offence, the following “three cumulative requirements” EADS (1) must be satisfied: (1) the offence must be committed by a Ecuador (2) person acting as a representative, director or manager, a person exercising powers of administration or supervision, or a person Egypt (4) under the “direction or supervision” of one of the Eli Lilly (1) aforementioned persons; (2) the offence must be committed for Enforcement Agency Policy the direct and immediate benefit or interest of the legal entity. (20) No offence is committed where the natural person commits the Enforcement Agency Speeches offence exclusively in his/her own interest or in the interest of a (24) third party; and (3) the offence must have been made possiblehttp://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  4. 4. FCPA Professor: Chile as a consequence of a failure of the legal entity to comply with ENI (3) its duties of management and supervision. An entity will have Ensco (1) failed to comply with its duties if it violates the obligation to Equitorial Guinea (2) implement a model for the prevention of offences, or when having implemented the model, it was insufficient." Extradition (1) Facilitating Payments (14) As to the final element, the OECD report states as follows. “The Faro Technologies (2) final cumulative requirement for responsibility stresses that the FCPA (1) offence must have been made possible as a consequence of the failure of the legal person to comply with its duties of FCPA Inc. (17) administration and supervision. The entity will have failed to FCPA Jurisprudence (27) comply with its duties if it violated the obligation to implement FCPA Reform (8) a model for the prevention of offences, or when having implemented the model, the latter was insufficient. It shall be FCPA Related Charges (2) considered that the functions of direction and supervision have FCPA Scholarship (8) been met if, before the commission of the offense, the legal FCPA Sentences (13) person had adopted and implemented organization, administration and supervision models, pursuant to the following FCPA Statistics (6) article, to prevent such offenses as the one committed.” FCPA Trial (5) Fees and Expenses (1) The minimum features of a prevention system under the law are Fernando Maya Basurto (1) as follows: identify the different activities or processes of the entity, whether habitual or sporadic, in whose context the risk Financial Services Industry (1) of commission of the offences emerges or increases; establish Flavio Ricotti (2) protocols, rules and procedures that permit persons involved in Food Industry (1) above-mentioned activities or processes to program and implement their tasks or functions in a manner that prevents the Foreign Issuers (3) commission of the indicated offences; identify procedures for Foreign Nationals (4) the administration and auditing that allow the entity to impede Foreign Official (68) their use in the listed offences; establish internal administrative sanctions, as well as procedures for reporting or pursuing Foreign Officials (2) pecuniary responsibility against persons who violate the Furmanite (1) prevention system; introduce the above-mentioned duties, Gabon (2) prohibitions and sanctions into the internal regulations of the Garth Blackwater (1) legal person, and ensure that they are known by all persons bound to apply it (workers, employees, and service providers). General Electric (1) Georgia (1) The OECD report states - as to the minimum requirements as Germany (2) follows. “It also aims to introduce a system of self-regulation by companies. Having a code of conduct on paper will not be Ghana (3) sufficient to avoid responsibility. If prosecutors can prove that Giffen (7) the code does not meet the minimum requirements of or that it Global Crossing (1) is not implemented, the company can be responsible for the offence.” GlobalSantaFe (2) Goldman Sachs (1) Under Chilean law, “the failure to comply with duties of Greece (7) management and supervision is an element of the offence rather greement (1) than a defence. Therefore the burden of proof lies on prosecutors, i.e. it will be up to prosecutors to prove that the Green (3) entity failed to comply with its duties of management and Greens (4) supervision.” Guest Posts (32)http://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  5. 5. FCPA Professor: Chile The OECD report notes as follows. “This will require prosecutors H-P (4) to prove that the company failed in the design and/or Haiti (9) implementation of the offense prevention model including why, Halliburton (9) in the circumstances, the prevention model was insufficient. This would appear to also require the prosecutor to establish Harris Corporation (2) that this failure made perpetration of the offence possible.” Helmerich and Payne Inc. (3) Honduras (4) As noted in the OECD report, the Chilean “standard of liability is HR 2152 (2) inspired from the Italian system of liability of legal persons" (discussed below). HR 5366 (4) HR 5837 (1) Germany HSBC Holdings (1) German law implementing the OECD Convention entered into Hungary (3) force on February 15, 1999. IBM (2) Import Issues (1) German law establishes the liability of legal persons, including liability for the foreign bribery offence, under an administrative Inc. (1) (i.e. non-criminal form) act. India (4) Individual Enforcement Action Pursuant to the administrative act, “the liability of legal persons (6) is triggered where any “responsible person” (which includes a Indonesia (7) broad range of senior managerial stakeholders and not only an authorised representative or manager), acting for the Innospec (11) management of the entity commits i) a criminal offence Internal Controls (9) including bribery; or ii) an administrative offence including a International Initiatives (4) violation of supervisory duties which either violates duties of the legal entity, or by which the legal entity gained or was supposed Investigative Fees (1) to gain a “profit”.” Iran (1) Iraq (13) As noted in the OECD report, “in other words, Germany enables corporations to be imputed with offences i) by senior managers, Iraq Oil For Food (1) and, somewhat indirectly, ii) with offences by lower level Italy (1) personnel which result from a failure by a senior corporate Ivory Coast (1) figure to faithfully discharge his/her duties of supervision.” Jamaica (2) The OECD report states that the “standards for a violation of James Tillery (1) supervisory duties include consideration of factors such as Japan (1) whether the company has in place a monitoring system or in- Jefferson (1) house regulations for employees.” Jeffrey Tesler (4) Hungary JGC of Japan (4) Joe Summers (1) Hungarian law implementing the OECD Convention entered into force on March 1, 1999. Joel Esquenazi (3) John Iacobucci (1) In 2004, a separate law was enacted specifying the individuals John Joseph OShea (5) whose actions can trigger the liability of the legal person. John Warwick (3) The OECD report states as follows. “The specific persons and Johnson and Johnson (4) additional conditions for liability are defined as follows: (i) the Joint Venture (1) bribery is committed by one of the members or officers [of thehttp://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  6. 6. FCPA Professor: Chile Jorge Granados (1) legal entity] entitled to manage or represent it, or a supervisory board member and/or their representatives acting within the Joseph Lukas (1) legal scope of activity of the legal person ; (ii) the bribery is Jurisdiction (6) committed by one of the members of the legal entity or an Jury Instructions (1) employee acting within the legal scope of activity of the legal person provided the bribery could have been prevented by the Kazakhstan (9) chief executive fulfilling his supervisory or control obligations; KBR (8) and (iii) the bribery is committed by a third party individual, Keith Lindsey (10) provided that the legal entity’s member or officer entitled to Kellogg Brown and Root (2) manage or represent the it had knowledge of the facts.” Kenya (2) According to the OECD report, the relevant law does not provide Knowledge (3) any guidance as to the necessary degree of supervision to avoid Korea (3) liability for bribery. Kozeny (3) Italy Kyrgyzstan (3) Latin Node (2) Italian law implementing the OECD Convention entered into force on October 26, 2000. Latvia (1) Layne Christensen (1) Under Italian law, “criminal liability cannot be attributed to Legislative History (15) legal persons” however, “administrative liability may be Leo Winston Smith (2) attributed to legal persons for certain criminal offences (including foreign bribery) committed by a natural person. Libya (4) Lindsey Manufacturing (11) The relevant administrative decree provides a “defence of Lobbying (1) organisational models” to a body which makes reasonable efforts to prevent the commission of an offence. Lockheed (1) Logistics (1) The OECD report states as follows. “… [A] body is not liable for Lucent (6) offences committed by persons in senior positions if it proves the following. First, before the offence was committed, the Lyondellbasell Industries (1) body’s management had adopted and effectively implemented Mabey Johnson (3) an appropriate organisational and management model to Macedonia (1) prevent offences of the kind that has occurred. Second, the Macmillan Publishers (1) body had set up an autonomous organ to supervise, enforce and update the model. Third, this autonomous organ had sufficiently Madagascar (1) supervised the operation of the model. Fourth, the perpetrator Magyar Telekom (2) committed the offence by fraudulently evading the operation of Malawi (1) the model.” The defence of organisation models operates as a full defence which completely exculpates a legal person. Malaysia (3) Man SE (1) The relevant administrative decree stipulates the essential Manuel Caceres (1) elements of an acceptable organisational model described in the OECD report as follows. “First, the model must identify activities Manuel Salvoch (1) which may give rise to offences. Second, the model must define Manufacturing Industry (1) procedures through which the body makes and implements Martin Eric Self (2) decisions relating to the offences to be prevented. It must also Maxwell Technologies (4) prescribe procedures for managing financial resources to prevent offences from being committed. Third, the model must Merger Issues (6) oblige the internal organ responsible for supervision and Mexico (12)http://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  7. 7. FCPA Professor: Chile enforcement to provide information to the body. Finally, the Micrus (1) model must include a disciplinary system for non-compliance.” Mining Industry (1) Japan Mongolia (1) Monitor (12) Japanese law implementing the OECD Convention entered into force on February 15, 1999 . Monsanto (1) Montenegro (1) “Under Japanese law, criminal responsibility of a legal person is Monty Fu (1) based on the principle that the company did not exercise due Morgan Stanley (1) care in the supervision, selection, etc. of an officer or employee to prevent the culpable act. Mozambique (2) MW Kellogg (1) The burden rests on the legal person to prove that due care was NATCO Group (2) exercised. Where a legal person raises the defence, a person must be identified as having exercised due care, etc., and the Natures Sunshine Products Inc court must determine whether it was exercised properly having (2) regard to the nature of the legal person and the circumstances Natures Sunshine Products Inc. of the case.” (1) Netherlands (1) Korea Nexus Technologies (5) Korean law implementing the OECD Convention entered into Nguyens (2) force on February 15, 1999. Nicaragua (1) Nigeria (26) Korean law establishes the criminal responsibility of legal persons for the bribery of a foreign public official, however, a Noble Corporation (4) legal person is exempt from liability where it has paid “due Non-Prosecution Agreement attention” or exercised “proper supervision” to prevent the (21) offence. Non-ProsecutionCongressional Activity (1) The statute itself does not provide information about what Obtain or Retain Business (6) constitutes “due attention” or “proper supervision.” A representative of the Supreme Public Prosecutor’s Office OECD (11) informed the OECD that “the exemption is triggered when a Oil for Food Enforcement director or ‘superior person’ exercises due attention.” The Action (1) Explanatory Manual published by the Ministry of Justice states Opinion Procedure Release that “it is difficult to standardize the extent of attention or (11) supervision in deciding whether a legal person can be exempted from criminal punishment.” The Explanatory Manual further Orthofix International (2) states that whether the exemption applies depends upon Oscar Meza (1) “general circumstances such as the motive and background that Ousama Naaman (4) led to the bribery, intervention of exclusive members of the Pacific Consolidated Industries legal person, whether it was informed earlier, and how much (1) effort was usually made by the corporation to prevent bribery, etc.” and that companies involved in international business must Pakistan (1) prevent violations of the law by all employees and executives of Panalpina (7) the company “through sufficient necessary management”. Panama (5) Poland Paradigm BV (1) Paul Novak (2) Polish law implementing the OECD Convention entered into forcehttp://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  8. 8. FCPA Professor: Chile PBSJ Corp. (5) on February 4, 2001. Permit / License Payments (3) Polish law provides “a noncriminal form of responsibility for Permits / Licenses / Customs / collective entities.” Among the requirements for liability is the Tax (1) offence was committed “in the effect of at least absence of due Peterson (1) diligence in electing the natural person [committing the act] or Pfizer (2) of at least the absence of due supervision over this person by an authority or a representative of the collective entity.” Pharmaceutical Industry (6) Philippines (1) According to the relevant Polish legislative history, “the Poland (2) perpetration of a prohibited act by a natural person will trigger liability of the Ports Engineering Consultants Corporation (4) collective entity where the act occurred as a result of negligence on the part of the authority or representative of the Portugal (1) collective entity.” Potpourri (1) Pride International (8) Portugal Principles of Federal Portuguese law implementing the OECD Convention entered into Prosecution of Business force on June 9, 2001. Organizations (2) Private Right of Action (3) Under Portuguese law relevant to corruption in international Proclamation 7750 (4) business transactions, legal persons can be liable for conduct Qatar (1) committed “on their behalf and in the collective interest by natural persons occupying a leadership position within the legal RAE Systems (3) person structure” or by “whoever acts under the authority” of Raytheon (1) such natural persons. Related Civil Litigation (6) However, “[t]he liability of legal persons and equivalent entities Reputational Damage (4) is excluded when the actor has acted against the orders or Research Tools (3) express instructions of the person responsible.” Resource Extraction Industry (3) Sweden Richard Bistrong (3) Swedish law implementing the OECD Convention entered into Rino International Corp. (1) force on July 1, 1999. Rockwell Automation (1) Romania (1) Under Swedish Law, only natural persons can commit crimes. However, pursuant to the Swedish Penal Code, a “kind of quasi- Ronald Schultz (1) criminal liability is applied to an ‘entrepreneur’ (a general term Royal Dutch Shell (4) meaning “any natural or legal person that professionally runs a Russia (9) business of an economic nature) for a ‘crime committed in the exercise of business activities.’” Saudi Arabia (2) Schering-Plough (2) However, one requirement under the Penal Code is that “the Schlumberger (1) entrepreneur has not done what could reasonable be required of him for prevention of the crime.” SciClone Pharmaceuticals (3) SEC (12) Switzerland SEC Enforcement Action (5) Securency International (1) Swiss law implementing the OECD Convention entered into forcehttp://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  9. 9. FCPA Professor: Chile on May 1, 2000. Self Reporting (1) Sensata Technologies (1) Article 100quater of the Swiss Criminal Code requires “defective Sentencing Guidelines (3) organisation as a condition for corporate criminal liability.” Serbia (1) In order to incur criminal liability, “the enterprise must not have Serious Fraud Office (35) taken all reasonable and necessary organisational measures to SFO (2) prevent the individual from committing the offence.” Shu Quan-Sheng (1) Under Swiss law, the burden is on the prosecutor to furnish Siemens (21) proof of defective organization and according to Swiss Smith and Wesson (2) authorities contacted by the OECD “steps should be taken to Snamprogetti (3) assess whether employees have been sufficiently informed, supervised and controlled” and “the fact that an enterprise is SOEs (1) organised in compliance with international management South Korea (1) standards will not be sufficient to rule out all liability on its Sovereign Wealth Funds (3) part; it will be one element to take into consideration among others …”. In the view of Swiss authorities, “ shifting the burden Stanley (1) of proof in criminal cases would contravene Article 6 of the State Department (1) European Convention on Human Rights.” Statoil (3) Posted by Mike Koehler at 5:00 AM 0 comments Statute of Limitations (1) Labels: Australia, Chile, Compliance Defense, FCPA Reform, Steve Lee (8) Germany, Hungary, Italy, Japan, Korea, OECD, Poland, Steven Lee (1) Portugal, Sweden, Switzerland Successor Liability (3) Sudan (1) Newer Posts Home Older Posts Sweden (1) Subscribe to: Posts (Atom) Switzerland (1) Syncor (1) Taiwan (2) Talecris (1) Tanzania (1) Tax Payments (1) Team Inc. (2) Technip (5) Technology Industry (1) Telecommunications Industry (3) Tenaris (2) Tesler (1) Thailand (6) Third Parties (1) Tidewater (3) Tobacco Industry (3) Transocean (3)http://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  10. 10. FCPA Professor: Chile Transparency International (3) Travel Act (1) Trinidad (1) Turkey (2) Turkmenistan (1) Tyson Foods (2) U.K. Bribery Act (7) U.S. Bribery Statute (1) U.S. v. Kay (4) UN Convention Against Bribery (1) United Arab Emirates (1) United Kingdom (33) United Nations (2) Universal Corporation (5) UTStarcom Inc. (3) Uzbekistan (2) Venezuela (4) Veraz Networks (2) Vetco (1) Victims (3) Vietnam (2) Voluntary Disclosure (20) Wehr Group (1) Whistleblowers (6) WikiLeaks (1) Willbros Group (4) William Jefferson (5) Wojciech (1) Wojciech Chodan (4) World Bank (5) Year in Review 2009 (1) Year in Review 2010 (7) Year in Review 2011 (2) Yemen (1) York (2) Blog Archive ▼  2011 (136) ►  July (10) ▼  June (21)http://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  11. 11. FCPA Professor: Chile Report Cards The Compliance Defense Around The World Mission Creep At The SEC? Breuer On The DOJs "Comprehensive Approach To Fig... What Does The SEC FCPA Unit Chief Do? Summer Reading For Representative Conyers Global Financial Integrity Responds ICE Appeal Receives Chilly Reception At 11th Circu... Russian FCPA: The Law Has Been Signed, Will The C... Carson Defendants Move To Dismiss Travel Act Count... House Hearing - Overview and Observations House Hearing - Pregame Assessing the Power of the SEC to Impose Monetary ... Friday Roundup Significant dd-3 Development in Africa Sting Case Branch Office Of The Prosecutor Chamber of Commerce Blasts FCPA-Related Civil Liti... What Others Are Saying About The SECs First DPA Scarboro to Simpson Thatcher Survey Says ... How Do Your Goods Get Out Of China? ►  May (20) ►  April (22) ►  March (23) ►  February (19)http://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]
  12. 12. FCPA Professor: Chile ►  January (21) ►  2010 (250) ►  2009 (81) Search This Blog Search powered by Sitemeterhttp://fcpaprofessor.blogspot.com/search/label/Chile[29-08-2011 23:00:04]

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