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Nov 14, 2012

The New FCPA Guide: The DOJ and the SEC Do Not Break New Ground But Offer Useful Guidance and Some Ominous Warnings

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On November 14, 2012, the US Department of Justice and the Securities and Exchange Commission issued the long-promised guidance outlining their interpretation of critical elements of the US Foreign Corrupt Practices Act (FCPA), providing some helpful guidance concerning the design and application of anti-corruption compliance programs, and explaining some of their enforcement policies concerning prosecution and resolution. Although much of this information has been available through reading tea leaves of prior enforcement actions, the Guide provides some useful insight while also some ominous warnings of the aggressive nature of some of the government’s interpretations and enforcement policies.

View full memo, "The New FCPA Guide: The DOJ and the SEC Do Not Break New Ground But Offer Useful Guidance and Some Ominous Warnings"

Authors and Contributors

Philip Urofsky

Partner

Litigation

+1 202 508 8060

+1 202 508 8060

Washington DC

Stephen Fishbein

Partner

Litigation

+1 212 848 4424

+1 212 848 4424

New York

Danforth Newcomb

Of Counsel

Litigation

+1 212 848 4184

+1 212 848 4184

New York

Patrick D. Robbins

Partner

Litigation

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+1 415 616 1210

San Francisco

Paula Howell Anderson

Partner

Litigation

+1 212 848 7727

+1 212 848 7727

New York

Jo Rickard

Of Counsel

Litigation

+44 20 7655 5781

+44 20 7655 5781

London

Brian G. Burke

Partner

Litigation

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+1 212 848 7140

+86 21 6136 5000

+86 21 6136 5000

New York