The FCPA Guidance Road Map

On November 14, 2012, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) issued A Resource Guide on the U.S. Foreign Corrupt Practices Act (the Guidance), approximately one year after the government announced its intention to do so. Although the Guidance does not break any new ground, it does provide a valuable tool for outside and in-house counsel alike to use as a reference point for the government's positions on almost all salient FCPA issues. Statements made by U.S. government officials subsequent to its release further clarified the scope of the Guidance.