Ethisphere's Business Ethics Leadership Alliance Latin America Roundtable

MoFo's Ruti Smithline and Jerry Gomez Galvis, both born and raised in Colombia, led Ethisphere's Business Ethics Leadership Alliance (BELA) Latin America Roundtable on July 17, 2023. In this virtual discussion, Ruti and Jerry addressed what companies operating in Latin America need to know about recent corporate enforcement and compliance policy updates. The recent developments addressed included:

• Recent case studies outlining continued coordination between the U.S. and Latin American governments;
• Recent revisions to DOJ’s Evaluation of Corporate Compliance Programs for the first time in nearly three years to include guidance on corporate policies and monitoring of third-party messaging applications and off-channel communications, a topic that is particularly pertinent for companies operating in Latin America, where third-party messaging platforms like WhatsApp are the norm for business communications;
• The launch of DOJ’s Pilot Program on Compensation Incentives and Clawbacks, which increases the complexity of corporate compliance expectations, in addition to strategic considerations regarding local employment law and executive compensation; and
• Recent revisions to DOJ’s Corporate Enforcement Policy compared against the newly announced voluntary self-disclosure policy for all U.S. Attorney’s Offices.

Learn more about the event.