Foreign Corrupt Practices Act, Bribery and International Anti-Corruption Update

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DOJ and SEC Issue Guidance on FCPA Matters -

After months of delays, the Securities Exchange Commission (“SEC”) and Department of Justice (“DOJ”) released its guidance on matters regarding the U.S. Foreign Corrupt Practices Act (“FCPA”). On November 14, 2012, the DOJ and the SEC released a 120-page “Resource Guide” to the FCPA. (Click here to see the report.)

The agencies described the guidance as “an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.” Well, that’s not quite true. Much of the guidance does not change or add to any of the positions advanced by the agencies in its prior enforcement actions or prior advisory opinions.

Please see full alert below for more information.

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DOJ
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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