Today, the Securities and Exchange Commission and the Department of Justice released A Resource Guide to the U.S. Foreign Corrupt Practice Act. The eagerly anticipated guide addresses a broad array of matters under the FCPA including the scope of the FCPA, its foreign official definition, gifts, travel and entertainment expenses, the facilitative expenses exception, successor liability, FCPA corporate compliance programs and other topics. We are reviewing the comprehensive 120-page guide and will provide updates in the coming days.
You can read the press release here.
Thomas G. Appleman
Matthew P. Allen