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Harry Cassin
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Andy Spalding
Senior Editor

Jessica Tillipman
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Richard L. Cassin
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Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Shruti J. Shah
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Russell A. Stamets
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Eric Carlson
Contributing Editor

DOJ and SEC release ‘unprecedented’ joint FCPA guidance

The DOJ and SEC today released a 120-page FCPA resource guide.

It’s available in pdf here.

The foreword, signed today by the DOJ’s Lanny Breuer and the SEC’s Robert Khuzami, says:

The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities. We are proud of the many lawyers and staff who worked on this project, and hope that it will be a useful reference for companies, individuals, and others interested in our enforcement of the Act.

Some items in publication are an introduction about corruption and the FCPA, who’s covered, the business purpose test, knowledge, ‘anything of value,’ gifts, travel and entertainment, charitable contributions, who is a ‘foreign official,’ facilitating payments, corporate liability, successor liability, aiding and abetting, statute of limitations, related offenses, compliance programs, and more.

Lanny Breuer said: ‘The fight against corruption is a law enforcement priority of the United States. Our FCPA enforcement is critical to protecting the integrity of markets for American companies doing business abroad, and we will continue to make clear that bribing foreign officials is not an acceptable shortcut. The guide is an important illustration of our transparency and a useful reference for companies and individuals who wish to act responsibly and in compliance with the law.’

We’ll have more coverage soon.

The DOJ’s release is here and the SEC’s is here.

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