Here’s what we heard from Jan Handzlik, left, about Wednesday’s FCPA guidance from the DOJ and SEC.
‘The new guidance is, in a word, underwhelming. It’s doubtful U.S. companies and individuals trying to understand the consequences of their actions when doing business abroad will find much real guidance here.… Continue Reading
On the inside front cover of the joint DOJ and SEC guidance released Wednesday, there’s a disclaimer that what follows is non-binding.
‘As such,’ the disclaimer continues, ‘it is not intended to, does not, and may not be relied upon to create any rights, substantive or procedural, that are enforceable at law by any party, in any criminal, civil, or administrative matter.… Continue Reading
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:
… Continue Reading
The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.
Late this summer, press outlets reported on anonymous claims that the Department of Justice and Securities and Exchange Commission likely would be releasing their long awaited FCPA Guidance in advance of an annual OECD Working Group on Bribery meeting on October 10, 2012.… Continue Reading