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Lost in translation: The difficulties of implementing a global compliance program

Ann L. Straw ( is U.S. General Counsel at Votorantim Cimentos North America, Inc. (VCNA), in Bridgeview, IL.

I am the U.S. General Counsel of a multinational conglomerate (VCNA) operating in North America, South America, Europe, Asia, and Africa. VCNA’s businesses cover a spectrum of industries, including mining, transportation, construction, pulp and paper, food products, insurance, and banking. VCNA is headquartered in Sao Paulo, Brazil, where economic and political strife have caused a high degree of marketplace chaos for the past several years. In the midst of this chaos, the company has maintained a fantastic equilibrium—free from scandal or corruption charges. But obviously the company is being hurt by the economic fallout that has resulted from multiple ongoing investigations into corruption at many levels of government and commerce in Brazil.

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