SEC and Justice Department Release Resource Guide to the U.S. Foreign Corrupt Practices Act ("FCPA")

The Department of Justice and the SEC have issued updated guidance on the enforcement of the Foreign Corrupt Practices Act (FCPA). The updated guidance is essentially an expansion of a prior Lay Person’s Guide, but now includes the elements and requirements of the FCPA, the standards of prosecution, and the opinion release procedures (which were previously published separately). Beyond that, the guidance lists useful hypotheticals that are representative of cases that have been the subject of prior enforcement actions in the past and also discusses the magnitude, and provides examples, of past declinations.

View guide in full here (links externally to SEC website). See also: Press Release.