On November 14, 2012, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) published A Resource Guide to the U.S. Foreign Corrupt Practices Act. The comprehensive, 120-page guide emphasizes at the outset that FCPA enforcement remains a priority for U.S. authorities. While non-binding on the government, the guide provides companies with a valuable window into the government’s thinking on the interpretation and enforcement of the FCPA. As the enforcement actions cited in the guide make clear, the stakes in this area are high. And the importance of understanding and complying with the FCPA has only increased with the enactment of the Dodd-Frank Act’s whistleblower provisions, which provide substantial monetary incentives for individuals to report suspected FCPA violations to the SEC.
http://www.kirkland.com/files/alerts/111912.pdf
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