Peru FCPA lawyer
The Foreign Corrupt Practices Act (FCPA) is a US federal law that prohibits bribery of foreign officials to obtain or retain business, and it applies to US companies and individuals operating in Peru. Law Offices of SRIS, P.C., a US law firm with an international clientele, provides FCPA compliance counseling, internal investigations, and defense representation for matters involving Peru. Mr. Sris, the firm’s founder and a former prosecutor, leads the US-law side of every engagement. For Peru-law dimensions—such as local anti-corruption statutes, corporate governance requirements, and evidence gathering—the firm collaborates with Martín Mayandía, Of Counsel, who is admitted to practice law in Peru. Mr. Mayandía is not admitted to practice law in the United States. This coordinated approach allows the firm to address both the US regulatory exposure and the on-the-ground realities in Peru. To discuss an FCPA matter with a Peru-aware US attorney, call (888) 437-7747.
What the FCPA Covers and Why It Matters for Peru-Related Business
The FCPA’s anti-bribery provisions, codified at 15 U.S.C. § 78dd-1 (issuers), § 78dd-2 (domestic concerns), and § 78dd-3 (certain foreign persons acting in US territory), make it unlawful to offer, pay, promise, or authorize anything of value to a foreign official for the purpose of obtaining or retaining business. The statute also imposes accounting and internal-controls requirements on issuers. The US Department of Justice and the Securities and Exchange Commission jointly enforce the FCPA, and both agencies have made clear that the law reaches conduct connected to any country, including Peru. For a US company with operations, subsidiaries, or business partners in Peru, the FCPA applies to interactions with Peruvian government officials, employees of state-owned enterprises, and political candidates. Even the actions of a third-party agent can create liability if the US company knew or should have known of the improper payment. The DOJ’s FCPA Unit and the SEC’s FCPA page publish enforcement actions that frequently involve Latin American jurisdictions, underscoring the need for proactive compliance.
Peru’s own anti-corruption framework—including the Criminal Code provisions on bribery and the recently strengthened corporate liability regime—adds a second layer of risk. A US company that violates the FCPA in Peru may also face Peruvian criminal or administrative proceedings. The firm’s dual-jurisdiction approach, with Mr. Sris handling the FCPA analysis and Martín Mayandía advising on Peruvian law, helps clients navigate both sets of rules without creating unauthorized-practice-of-law exposure.
How Mr. Sris and His Of Counsel Network Handle FCPA Matters Involving Peru
Mr. Sris and the firm’s Of Counsel network provide coordinated US-law and Peru-law guidance for FCPA compliance, internal investigations, and enforcement defense. On the US side, Mr. Sris—admitted in Virginia, Maryland, the District of Columbia, New Jersey, and New York—leads the FCPA analysis. He advises on the statute’s jurisdictional reach, assesses whether particular conduct falls within the anti-bribery or accounting provisions, and, when appropriate, guides clients through the DOJ’s voluntary self-disclosure process. He also represents clients in SEC and DOJ investigations and in any resulting litigation.
For the Peru-law dimension, the firm works with Martín Mayandía, Of Counsel, who is admitted to practice law in Peru. Mr. Mayandía is not admitted to practice law in the United States. His role is limited to matters of Peruvian law—such as interpreting local bribery statutes, advising on the validity of government contracts under Peruvian law, and assisting with the collection of evidence in Peru—in collaboration with the US-admitted attorneys of the firm. This division of responsibility ensures that every aspect of a cross-border FCPA matter is handled by an attorney licensed in the relevant jurisdiction, consistent with US and Peruvian bar rules.
About Mr. Sris and the firm’s Of Counsel Network
Mr. Sris, founder of Law Offices of SRIS, P.C., is a former prosecutor admitted in Virginia, Maryland, the District of Columbia, New Jersey, and New York. He founded the firm in 1997 and has built a practice that serves clients across the United States and internationally. Mr. Sris testified before the Virginia House Courts of Justice Committee in support of 2019 HB 635 (chief patron Del. David Bulova), the bill that became the 2019 revision to Va. Code § 20-107.3(g). His experience includes representing individuals and companies in complex federal investigations, including FCPA matters.
Mr. Sris and his Of Counsel bring extensive combined legal experience. For Peru-related engagements, the firm’s Of Counsel network includes Martín Mayandía, who is admitted to practice law in Peru. Mr. Mayandía is not admitted to practice law in the United States. His practice with the firm is limited to matters of Peruvian law and to serving as a liaison for international clients with the US-admitted attorneys of the firm. This structure allows the firm to offer clients a single point of contact for cross-border FCPA issues while maintaining strict jurisdictional separation.
Frequently Asked Questions
What is the FCPA?
The Foreign Corrupt Practices Act is a US federal law that prohibits bribery of foreign officials and requires certain companies to maintain accurate books and records and adequate internal controls. Enacted in 1977 and amended in 1998, the FCPA has two main parts: the anti-bribery provisions, which apply to US persons and companies, and the accounting provisions, which apply to issuers of securities registered in the US. Violations can lead to criminal fines, imprisonment, and civil penalties. The DOJ and SEC enforce the statute, and both agencies have emphasized that the FCPA applies to conduct anywhere in the world, including Peru.
Does the FCPA apply to a US company doing business in Peru?
Yes, the FCPA applies to any US company, citizen, or resident, and to any issuer of US securities, regardless of where the conduct occurs. If a US company pays a bribe to a Peruvian government official—or authorizes a third party to do so—the company and the individuals involved can face FCPA liability. The statute also reaches certain foreign persons who act in furtherance of a bribe while in US territory. Because Peru is a significant trading partner, US companies with operations, suppliers, or customers in Peru should implement robust FCPA compliance programs.
Do I need a Peru-licensed lawyer for an FCPA investigation involving Peru?
While the FCPA itself is a US statute, an investigation that involves evidence, witnesses, or local law in Peru often benefits from the involvement of a Peru-licensed attorney. A Peru-admitted lawyer can advise on Peruvian data-privacy rules, assist with document collection, and interpret local anti-corruption statutes that may run parallel to the FCPA. Law Offices of SRIS, P.C. collaborates with Martín Mayandía, Of Counsel, who is admitted in Peru and not admitted in any US state bar, to handle those Peru-law aspects while Mr. Sris manages the US FCPA defense.
How does the firm handle the US-Peru cross-border aspect of an FCPA matter?
The firm divides the work along jurisdictional lines: Mr. Sris and the US-admitted attorneys handle all US-law issues, and Martín Mayandía, the firm’s Peru Of Counsel, handles Peru-law issues. This structure ensures that no attorney practices law in a jurisdiction where they are not admitted. The two sides coordinate closely, but the US attorney remains responsible for the FCPA analysis, interactions with US enforcement agencies, and any US court proceedings. The Peru Of Counsel provides local law guidance and logistical support in Peru.
What should I bring to an initial consultation about an FCPA matter involving Peru?
Bring any relevant correspondence, contracts, due-diligence reports, and internal communications that relate to the transaction or relationship at issue. If you have already received a subpoena, a document request, or a letter from the DOJ or SEC, bring that as well. The more information you can provide about the parties, the payments, and the business purpose, the better Mr. Sris can assess the FCPA exposure and the potential need for Peru-law input from Martín Mayandía. All consultations are confidential.
How can I contact the firm about an FCPA matter involving Peru?
Call Law Offices of SRIS, P.C. at (888) 437-7747 to schedule a consultation with Mr. Sris. The firm’s intake team can arrange a discussion that includes both Mr. Sris and, if appropriate, Martín Mayandía, the firm’s Peru Of Counsel, so that both the US and Peruvian dimensions of your matter are addressed from the outset.
For guidance on related cross-border compliance matters, contact Law Offices of SRIS, P.C. at (888) 437-7747.