Peru ISO 37001 counsel
Peruvian businesses seeking to demonstrate robust anti-bribery compliance increasingly adopt ISO 37001, the international standard for anti-bribery management systems. Whether your organization is a multinational operating in Peru, a Peruvian exporter facing U.S. Foreign Corrupt Practices Act (FCPA) requirements, or a local company preparing for certification, aligning internal controls with ISO 37001 helps meet the expectations of international partners and regulators. At Law Offices of SRIS, P.C., Mr. Sris and his Of Counsel network provide coordinated counsel on cross-border compliance strategies tailored to the Peruvian business environment. Mr. Sris, admitted in Virginia, Maryland, the District of Columbia, New Jersey, and New York, brings extensive experience advising clients on U.S. anti-corruption laws. For Peruvian-law dimensions, the firm collaborates with Martín Mayandía, Of Counsel for Peru. Mr. Mayandía is admitted to practice law in Peru; he is not admitted to practice law in the United States. Reach us at (888) 437-7747.
What This Cross-Border Practice Area Covers
ISO 37001 provides a globally recognized framework for implementing an anti-bribery management system that helps organizations prevent, detect, and address bribery. The standard, published by the International Organization for Standardization, outlines requirements for policies, risk assessment, due diligence, financial and non-financial controls, and reporting mechanisms. In Peru, the principal anti-corruption statute is the Código Penal Peruano, Título XVIII, supplemented by Law No. 30424 (corporate liability for corruption). An organization that aligns its practices with ISO 37001 can demonstrate a commitment to compliance that satisfies both Peruvian legal obligations and the expectations of foreign business partners — including companies subject to the Foreign Corrupt Practices Act.
The FCPA, enforced by the U.S. Department of Justice and the Securities and Exchange Commission, prohibits bribery of foreign officials by U.S. issuers, domestic concerns, and certain foreign persons acting in U.S. territory. A Peruvian company that is an issuer on a U.S. exchange, or that acts through a U.S. agent or subsidiary, may fall within FCPA jurisdiction. While ISO 37001 certification does not guarantee FCPA compliance, it serves as evidence that the organization has adopted reasonable anti-bribery controls. Because Peru is not subject to comprehensive U.S. sanctions (as of 2026), cross-border compliance engagements for Peruvian entities typically focus on the interplay between FCPA, Peruvian law, and international standards.
How Mr. Sris and His Of Counsel Network Handle These Matters
Mr. Sris serves as the responsible U.S. attorney, advising on FCPA risk assessment, internal investigations, and compliance program design, while Peruvian-licensed Of Counsel address matters of Peruvian law. This structure respects the jurisdictional boundaries essential in cross-border representation: the U.S.-licensed attorney handles the U.S.-law dimension, and the Peruvian-licensed attorney handles the Peruvian-law dimension. The firm does not itself practice Peruvian law; for clients who need Peruvian legal representation, Martín Mayandía can be engaged through his own practice, with the firm facilitating communication and ensuring that U.S. and Peruvian counsel work in concert.
A typical matter might involve a compliance gap analysis that evaluates FCPA exposure and Peruvian anticorruption requirements side-by-side, or assistance in preparing for an ISO 37001 certification audit where the certifying body requires a local legal opinion. Mr. Mayandía, who has been admitted to practice in Peru since 2009, is well positioned to advise on the Peruvian statutory framework, while the firm’s U.S. attorneys provide guidance that reflects the latest enforcement priorities of the DOJ and SEC. This dual-counsel approach keeps each attorney focused within their own licensure and gives the client a single point of coordination through Law Offices of SRIS, P.C.
About Mr. Sris and the Of Counsel Network
Atchuthan Sriskandarajah, Esq., known as Mr. Sris, is the Owner and Managing Attorney of Law Offices of SRIS, P.C., a U.S. law firm founded in 1997. He is admitted to practice in Virginia, Maryland, the District of Columbia, New Jersey, and New York. 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 U.S.-law practice spans two decades and includes representing clients in matters that intersect with foreign regulatory regimes.
To serve the firm’s international clientele, the firm’s Of Counsel network includes attorneys admitted in jurisdictions where cross-border matters frequently arise. Martín Mayandía serves as Of Counsel for Peru. He is admitted to practice law in Peru; he is not admitted to practice law in the United States. Through this collaboration, the firm can offer coordinated counsel that bridges U.S. anti-corruption requirements and Peruvian compliance standards without compromising licensure boundaries.
Frequently Asked Questions
What is ISO 37001?
ISO 37001 is an international standard issued by the International Organization for Standardization that specifies requirements for establishing, implementing, maintaining, and improving an anti-bribery management system. It covers topics such as anti-bribery policy, risk assessment, due diligence on business associates, financial and non-financial controls, reporting procedures, and investigation protocols. Certification is performed by independent accredited bodies and demonstrates that an organization has put in place a system to detect and prevent bribery. While ISO 37001 is not a law, it often serves as a benchmark for compliance with anti-corruption laws, including the FCPA and Peru’s domestic anticorruption statutes.
Does my Peruvian company need ISO 37001 to comply with the FCPA?
No — ISO 37001 certification is not required by the FCPA. The FCPA imposes obligations on certain U.S.-connected entities and individuals, and it does not reference any particular management standard. However, a robust anti-bribery management system aligned with ISO 37001 can significantly reduce the risk of violating the FCPA by establishing preventive controls and an internal culture of compliance. Many U.S. companies and regulators view ISO 37001 certification as evidence of a good-faith compliance effort, which may be a factor in evaluating an organization’s due diligence or reducing penalties in the event of a violation.
How should a Peruvian company approach ISO 37001 certification when it deals with U.S. parties?
Start by conducting a joint U.S.–Peru compliance gap analysis that maps FCPA exposure against Peruvian anticorruption laws and ISO 37001 requirements. An organization should identify the FCPA-risk points in its operations (e.g., transactions involving U.S. dollars, U.S. suppliers, or U.S.-listed affiliates) and then evaluate whether existing internal controls meet the standard’s criteria. A U.S.-licensed attorney can advise on FCPA obligations, while a Peruvian-licensed attorney can address local legal nuances. Engaging both before a certification audit helps the entity present a cohesive compliance picture to the certifying body and demonstrates seriousness about meeting both country-specific obligations.
Can a U.S. law firm advise on ISO 37001 certification in Peru?
A U.S. law firm cannot give legal advice on Peruvian law unless it does so through a Peruvian-licensed attorney handling the Peruvian-law component. At Law Offices of SRIS, P.C., Mr. Sris and the U.S.-licensed team focus on U.S. anti-corruption law, including FCPA, OFAC, and related regulations. For Peruvian-law dimensions of ISO 37001 certification — such as evaluating compliance with the Código Penal Peruano or Law No. 30424 — the firm facilitates collaboration with Martín Mayandía, who is admitted in Peru. This structure allows the client to receive integrated counsel while ensuring that each attorney practices within their licensed jurisdiction.
What is the penalty for an FCPA violation, and does Peru’s law impose similar consequences?
Under the FCPA, individuals face up to five years’ imprisonment per anti-bribery violation (15 U.S.C. § 78ff), while corporations may incur significant fines and disgorgement. In Peru, corruption offenses carry their own penalties under the Código Penal, including imprisonment and financial sanctions. Because the FCPA and Peruvian law operate independently, a single act of bribery could create exposure under both regimes. Cross-border counsel helps an organization understand these overlapping risks and build a compliance framework that addresses each statute’s requirements.