Brendan Cullen, a partner in Sullivan & Cromwell LLP’s Litigation Group, and Tony Lewis, co-head of the firm’s National Security Group, have contributed a chapter to the sixth edition of Latin Lawyer’s Guide to Corporate Compliance. Their chapter examines recent shifts in enforcement priorities, investigative methods, and prosecutorial discretion in Latin America. These trends are reflected in directives issued by the U.S. government.
The authors offer recommendations for multinational companies on creating compliance programs that align with legal requirements across different jurisdictions. They emphasize the value of maintaining strong compliance systems to help prevent potential issues and reduce risks for companies.
“It can prevent illicit conduct in the first place, it can detect it at the earliest possible stage if it does arise, and it can lessen or avoid many of the consequences that come with an enforcement action – not least of which could be a compliance monitor to help devise and implement a programme that should have been established in the first place,” Cullen and Lewis write.
Their work aims to assist organizations operating internationally as they navigate complex regulatory environments.