Top Seven Things You Need to Know About The New DOJ/SEC FCPA Guide

On November 14, the Department of Justice (DOJ) and the SEC issued their long-awaited “guidance” on the Foreign Corrupt Practices Act (FCPA) in the form of a “guide” called FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act. The guide’s stated aim is to “provide helpful information to enterprises of all shapes and sizes” about the approach taken by the DOJ and the SEC in enforcing the FCPA. As the guide notes, it is “an unprecedented undertaking . . . to provide the public with detailed information about [the agencies’] FCPA enforcement approach and priorities.”

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