FCPA - Off Again On Again - Maybe Both

In this episode of AML Conversations, Elliot Berman is joined by Christopher Sindik, Senior Director of Third‑Party Risk and Due Diligence at Blue Umbrella, for a deep dive into the Foreign Corrupt Practices Act (FCPA) and the recent deferred prosecution agreement involving Tigo Guatemala, Millicom, and the U.S. Department of Justice. Elliot and Christopher break down how the misconduct unfolded, why the joint‑venture structure created an environment ripe for corruption, and what lessons compliance professionals can draw from the case. The conversation explores practical strategies for strengthening third-party risk management, including intrinsic and acquired risk factors, enhanced controls for high‑corruption jurisdictions, and the critical role of data analytics and AI in detecting anomalies. They also discuss the importance of tone from the top, resource allocation for compliance programs, whistleblower protection, and how companies can ensure that legitimate services are properly documented and auditable. The episode highlights how proactive self-disclosure and robust compliance frameworks can significantly impact outcomes in enforcement actions.