U.S. Government Issues Guidance On Foreign Corrupt Practices Act

The resource guide issued by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) on November 14, 2012, addresses important topics for those doing business across the globe.  This new guidance does not alter the DOJ and SEC's focus on aggressively pursuing Foreign Corrupt Practices Act anti-bribery and accounting violations, so companies must continue to focus on maintaining a robust compliance program and assessing risk worldwide.

On November 14, 2012, the Criminal Division of the U.S. Department of Justice (DOJ) and the Enforcement Division of the U.S. Securities and Exchange Commission (SEC) issued a resource guide for the Foreign Corrupt Practices Act (FCPA) (the Guidance).  This long-awaited Guidance from the DOJ and SEC addresses a number of important topics for those doing business across the globe.  While much of the Guidance is not a departure from the positions taken by the U.S. government in recent cases, it does