Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
Arnold Y. Castillo brings more than 25 years of investigative experience to high-stakes matters across Latin America and the Caribbean. He specializes in complex corporate investigations, asset tracing, and anti-corruption matters, including FCPA and AML inquiries. He has led multijurisdictional teams on internal fraud, political risk, and due diligence assignments, often involving digital forensics and financial analysis.
Over the past 25 years working throughout Latin America and the Caribbean, Mr. Castillo has led and been involved in some of the region’s most high-stakes and complex corporate investigations into Foreign Corrupt Practices Act (FCPA), Bank Secrecy Act (BSA)/Anti-Money-Laundering (AML), asset tracing, construction internal fraud, environmental damage, money laundering, social conflict monitoring, and corruption in both government and corporate settings—often sparked by anonymous whistleblower reports. His extensive experience has allowed him to cultivate a wide-reaching source network of contacts across every country in the region, having worked in all of them and handled hostile situations for clients who had been defrauded by local partners.
As a recognized reputation management and crisis advisor, Mr. Castillo has provided independent, third-party assessments for clients facing public allegations, media exposure, or regulatory interest. He is often called upon to evaluate reputational damage, mitigate regulatory risk, and support high-stakes negotiations with U.S. authorities, compliance officers, and prospective partners.
His fact-finding background includes investigating internal fraud and corruption rings for multinational mining, energy, banks, and credit card corporations with multijurisdictional operations in the Andean region, Central America and the Caribbean where he deployed teams for intelligence-gathering assignments, IT digital evidence collection, and forensic accounting. Mr. Castillo has led hundreds of pre-transaction business intelligence, political risk, and due diligence investigations for foreign investors and international candidates applying for financial licenses worldwide. Mr. Castillo has led several investigation and litigation support teams on multiple occasions and presented testimony in arbitration proceedings in defense of his clients.
Mr. Castillo has been recognized by Lexology Index (formerly Who’s Who Legal) as a global leader in numerous Investigations & Digital Forensics rankings, praised for his sharp expertise, long-standing network, and professionalism in handling complex security and sensitive investigations matters. Lexology notes: “Known for integrating data-driven methodologies with investigative expertise, Mr. Castillo handles multi-jurisdictional fraud and compliance matters and is singled out for his ‘ability to quickly understand a matter‘ as well as his ‘deep knowledge of the industry.’”
Before joining Secretariat, Mr. Castillo held leadership roles at several leading international disputes and investigations consulting firms.
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
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