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"
