FCPA Guidance On 3rd-Party Liability Is Confusing

Law360, New York (November 30, 2012, 1:48 PM ET) -- The Foreign Corrupt Practices Act guidance is a terrific contribution to FCPA law and policy. I have the utmost respect and admiration for the U.S. Department of Justice and U.S. Securities and Exchange Commission professionals who enforce this law. They are true public servants. 

A testament to the importance of the FCPA guidance is the absence of any meaningful or persuasive criticism of the FCPA guidance. Of course, the FCPA paparazzi will try and strike fear in the hearts of corporate counsel and compliance officers in...
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