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The New Guidance

Ethisphere

In this article, Homer Moyer provides commentary on the recently released joint DOJ/SEC Resource Guide on the U.S. Foreign Corrupt Practices Act (the Guide). Overall, the Guide clarifies the law and how it is applied by the enforcement agencies, expressly confirms pre-existing enforcement practices and policies, and consolidates current agency thinking in a single, comprehensive reference source. The Guide addresses the issues raised by those championing changes to the FCPA, but does not revise the law or current enforcement policies.