Tagged: in-kind bribes

J&F Investimentos FCPA Settlement: Lessons Learned (Part IV of V)

J&F Investimentos (“J&F”) FCPA settlement presents a number of important lessons learned.  While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly obvious.  Despite J&F’s large global operations and expansion plans, J&F made no apparent effort to build an ethics and compliance program or implement basic compliance requirements, such as a Code of...