The Corficocolombiana FCPA Settlement: the Bribery Scheme (Part II of II)
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. The Corficocolombiana (“Corfico”) FCPA settlement underscores the significant risks when companies participate in large projects in foreign countries. Between 2012 and 2015, Corfico paid more than $23 million in bribes to high-ranking Colombian...