New FCPA Guidance: Important, But No Sea-Change

Law360, New York (November 21, 2012, 1:26 PM EST) -- On Nov. 14, 2012, the U.S. Department of Justice and the U.S. Securities and Exchange Commission issued their long-anticipated Resource Guide regarding the agencies’ enforcement of the Foreign Corrupt Practices Act. The 120-page guide addresses, among other things, (1) the definition of a foreign official, (2) gifts and entertainment, and (3) the “hallmarks” of an effective corporate compliance program. While the guide does not represent a significant departure from the agencies’ prior positions, it offers several important clarifications and hypothetical case studies that corporate counsel should...
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