For the first time since its initial publication in November 2012, the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) jointly published a revised edition of the Resource Guide to the US Foreign Corrupt Practices Act (“the Second Edition”). This guide provides the most up-to-date collective guidance of how the DOJ and SEC views and may approach FCPA investigations, enforcement actions and resolutions in the coming years. Boards and compliance professionals may find this a useful tool to monitor enforcer expectations and trends. While many of the changes were expected, some of these revisions may signal important priorities and positions US enforcement authorities may take in the future.
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