Marc Alain Bohn Discusses Potential Changes to FCPA Guidance in The FCPA Blog

"A closer look at the revisions to the FCPA Guide"
The FCPA Blog
08.06.15In this blog post, Marc Alain Bohn discusses reports that the Department of Justice (DOJ) and Securities & Exchange Commission (SEC) have in recent months quietly revised A Resource Guide to the Foreign Corrupt Practices Act (FCPA), the joint guidance the agencies issued in November 2012. Bohn clarifies that the changes identified as recent were in fact implemented years ago. "The discussion over these revisions, however, makes clear that the current process for updating the FCPA Guide is opaque, making it difficult to know whether and when changes have been made. As a result, practitioners relying on the FCPA Guide would be wise to consult the current online version of the guidance posted to the DOJ's and SEC's respective websites," Bohn said. "So should FCPA practitioners and other interested parties expect further changes to the FCPA Guide, as least in the near term? Probably not. The Guide has been subjected to intense scrutiny over the past two and a half years, and one would expect that any revisions or corrections the agencies were amenable to making have already been made."
Related Files
Related Links