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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About Matthew A. Lafferman
Matthew A. Lafferman is a member of Dentons' Litigation and Dispute Resolution and White Collar and Government Investigations practices. He represents financial institutions, corporations, and individuals in a wide range of disputes, including government and internal investigations, congressional inquiries, and litigation.
About Sara Holzschuh
Sara Holzschuh is a member of Dentons' White Collar and Government Investigations practice, advising and representing entities and individuals that are targets or subjects of government investigations or enforcement actions, and leading or conducting internal investigations into potential or alleged violations of cross-border anti-bribery and anti-money laundering laws, trade sanctions and export controls.
About J. Richard Kiefer
Dick Kiefer is Co-Leader of Dentons' national White Collar Crime and Government Investigations practice group. A veteran of approximately 100 jury trials in state and federal courts and dozens of state and federal appeals throughout the country and over 200 internal investigations, Dick has extensive experience in representing clients in cases involving health care fraud, tax fraud, mail fraud, wire fraud, money laundering, currency structuring violations, securities fraud, anti-trust violations, environmental crimes, public corruption and bribery, and myriad other federal and state criminal offenses.