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A Resource Guide to the U.S. Foreign Corrupt Practices Act

The DOJ And SEC's New Foreign Corrupt Practices Act (FCPA) Guide: Practical Guidance, No Shifts In Approach

On November 14, 2012, the DOJ and SEC released their much anticipated joint Resource Guide to the U.S. Foreign Corrupt Practices Act (the Guide). Those hoping for a new approach to FCPA enforcement - whether a step back from the agencies’ aggressive interpretations of the statue or the adoption of a compliance-based defense similar to the “adequate procedures” defense under the UK Bribery Act - will be disappointed.

A comprehensive tome of 120 pages, the Guide largely reiterates the agencies’ longstanding enforcement principles. Even so, the Guide promises to be a tremendously useful tool because it collects and rationalizes prior enforcement decisions and provides detailed guidance and hypotheticals in a number of areas. Moreover, the fact that the Guide was issued jointly is an important reassurance that the agencies have adopted14, a unified approach to FCPA enforcement.

Click through the headings above to find out more about the Guide and our assessment of the implications of the Guide.

 

Our Anti-Bribery and Corruption team

We provide expert advice on the full range of international anti-corruption issues, globally.

Read more about our practice, and view recent anti-bribery and corruption publications from around the world here .

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Kurt Wolfe
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