Multinational corporations with connections to the U.S. usually look to American authorities for guidance in the design and implementation of an effective anti-corruption compliance program. However, multinational corporations with operations in Latin America should also be aware of developing compliance guidance and expectations issued by governments throughout the region, including in Argentina, Brazil, Chile, Colombia, Costa Rica, Mexico and Peru. In a guest article, James Tillen and Alejandra Montenegro Almonte of Miller & Chevalier, with the assistance of summer associate Abi Hollinger, use the framework of the DOJ/SEC hallmarks of an effective anti-corruption compliance program to compare compliance expectations of the countries in the region with those in the United States and use data from Miller & Chevalier’s Latin America Corruption Survey to provide an assessment of what effect these laws are having. For more from the Survey, see “Managing Corruption in Latin America’s Police Forces
“ (Sep. 16, 2020).