The FCPA in 2012
The year 2012 will probably be remembered in the annals of FCPA history as the year of the Guidance (formally known as A Resource Guide to the US Foreign Corrupt Practices Act). Its release had been eagerly anticipated since Assistant Attorney General Lanny A Breuer announced in November 2011 that the government would issue detailed guidance on the FCPA. One year later, the Department of Justice and Securities and Exchange Commission jointly released a 120-page policy paper that, in some detail, sets forth the agencies’ views on the statute and criteria for bringing enforcement actions.
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