Recent Developments in Colombian Compliance Expectations

Colombia has a corporate compliance and transparency environment that can catch some multinational companies unawares. A strong compliance program is legally required, and those requirements can be strict, particularly with regard to gift-giving. There are new lobbying and whistleblower regulations on the horizon as well. The first article of this two-part series on Colombia’s enforcement environment reviewed the anti-corruption laws passed so far and analyzed a 2024 decree on self-disclosure incentives. This second part examines important aspects of doing business in Colombia, such as the rules on compliance program structure, gifts and facilitation payments, as well as the whistleblower protection law in the works, distilling insights shared by local legal experts. See “Latin American Corruption in the Crosshairs of the Biden Administration” (Apr. 14, 2021).

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