Last week was a busy week for compliance officers and FCPA practitioners. On November 14, the long-awaited FCPA guidance from the DOJ and SEC was released. In the following days, senior DOJ and SEC officials spoke at the American Conference Institute’s 28th National Conference on the Foreign Corrupt Practices Act in Washington, D.C. They revealed their thinking on the following topics, among others:
• the newly released guidance;
• expectations of companies’ compliance programs;
• self-reporting (not surprisingly, that companies should always pick up the phone); and
• their unwavering commitment to the aggressive FCPA enforcement we have seen in recent years...
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