The Department of Justice and the Securities and Exchange Commission have just released
A Resource Guide to the U.S. Foreign Corrupt Practices Act (the link is to the Department of Justice’s web site, which summarizes the guidance and has a link to download a PDF of the Resource Guide).
The Introduction states:
This resource guide, prepared by DOJ and SEC staff, aims to provide businesses and individuals with information to help them abide by the law, detect and prevent FCPA violations, and implement effective compliance programs.
I am not an attorney, so will not provide additional highlights in my normal fashion. Instead, I have included links to legal firms’ and experts' analyses.
Clearly, this should be read by internal audit leaders around the world (remember: most of the legal actions under the FCPA have been against non-U.S. corporations).