Homer Moyer commented on the recently released guidance from the U.S. government on the Foreign Corrupt Practices Act (FCPA).  The guidance was released in response to businesses who requested clearer definitions and exemptions within the FCPA, including the definition of who is a "foreign official."  Moyer said his initial impression was that the guidance did not represent an effort to expand the scope of FCPA prosecutions or a victory for efforts to curtail it. "It's obviously comprehensive, lengthy and thoughtful," Moyer said, noting that he was still studying the 130-page document. "I don't see this so far as a vehicle for either expanding the envelope or contracting it in light of criticisms or concerns."