January 26, 2013
The "new" DOJ-SEC Guidance to the U.S. Foreign Corrupt Practices Act.
Re: the much-heralded release in December of FCPA guidance by the Criminal Division of the U.S. Department of Justice and the Enforcement Division of the U.S. Securities and Exchange Commission. Does the new Resource Guide to the U.S. Foreign Corrupt Practices Act keep American companies acting abroad guessing about what constitutes bribery? Does its 130 pages "guide", even in a guidance-is-non-binding sort of way? Once again, what's a "foreign official"? What if any new defenses are really available to FCPA violations? What is the actual scope of gifts, entertainment and travel under the FCPA?
Posted by JD Hull at January 26, 2013 11:59 PM