Guidance On The U.S. Foreign Corrupt Practices Act

On 14 November 2012, the United States Department of Justice and Securities and Exchange Commission published FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Guide covers most of the important aspects of the FCPA. It also goes over guiding principles with respect to enforcement. It provides several clarifications, and useful case studies.

GUIDANCE ON INTERNAL COMPLIANCE POLICIES AND PROCEDURE

All companies operating abroad should have in place policies and procedures aimed at preventing and dealing with corruption. The Guide sets out ten components of an effective compliance program:

• A commitment from senior management to anti-corruption and ethical business practices, and a clearly articulated policy against corruption.