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New data reveal the growth of compliance in Latin America

Alejandra Montenegro Almonte ( is Vice Chair of Miller & Chevalier’s International Department in Washington, DC. James Tillen ( is the Chair of the International Department at Miller & Chevalier.

A perennial challenge for chief compliance officers (CCOs) is assessing corruption risk in their companies’ countries of operation. Many CCOs turn to Transparency International’s Corruption Perception Index (CPI), which annually ranks countries based on the perceived levels of corruption in their public sector generally. Companies use CPI scores to determine what amount of due diligence to conduct on a third party, what locations to audit, what employees to train, and whether to enter into a new market. Yet a CPI score does not tell the whole story for a particular country, and overreliance on the CPI can lead companies to miss specific risks or focus too many resources on low-risk areas.

With this challenge in mind, our firm, in partnership with several law firms across Latin America, began conducting a corruption survey of the countries in the region every four years to provide CCOs with more detailed corruption data to help organizations assess and address particularized risks within each jurisdiction. The 2020 survey[1] yielded important information about the changing corruption landscape in the region that CCOs will find useful in making risk-based decisions related to the region. It additionally assessed anti-corruption compliance practices, which can help CCOs benchmark their programs and determine where compliance concepts are accepted and where more efforts may be required to implement effective compliance components.

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