In a peculiar way, that signature line, crystalized my thinking about the latest Foreign Corrupt Practices Act (FCPA) Opinion Release from the Department of Justice (DOJ); that being Opinion Release 12-01 (12-01). As first noted by the FCPA Professor, in his post entitled, “DOJ’s Recent Opinion Procedure Release Creates Additional “Foreign Official” Confusion”, 12-01 is has a dated of September 18, 2012, but was apparently only publicly released last week. Whist listening to The Who classic What hearing “Won’t Get Fooled Again” See more +

In a peculiar way, that signature line, crystalized my thinking about the latest Foreign Corrupt Practices Act (FCPA) Opinion Release from the Department of Justice (DOJ); that being Opinion Release 12-01 (12-01). As first noted by the FCPA Professor, in his post entitled, “DOJ’s Recent Opinion Procedure Release Creates Additional “Foreign Official” Confusion”, 12-01 is has a dated of September 18, 2012, but was apparently only publicly released last week. Whist listening to The Who classic What hearing “Won’t Get Fooled Again” blasting away while I was riding it made me think of is the evolving nature of not only best practices under the FCPA but also the DOJ’s evolved thinking on the subject. So while the song’s ending line speaks of nothing changing, I realized the nature of changing nature of FCPA analysis is and can be changing. So rather than being confused, I think that the DOJ has underlined again the fact intensive nature of many of the analysis required under the FCPA and how companies, if they used a reasoned approach for a specific FCPA issue or problem, can go a long way towards protecting themselves from potential FCPA liability or exposure. See less -