DOJ and the SEC Issue Much-Anticipated FCPA Guidance
- Roger Witten, Kimberly Parker, Jay Holtmeier
- 11.19.2012
On November 14, 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) published their long-awaited joint guidance on the US Foreign Corrupt Practices Act (FCPA), entitled A Resource Guide to the U.S. Foreign Corrupt Practices Act (the Guide). It is unprecedented in federal law enforcement that DOJ and the SEC have provided the public with such detailed information on their joint FCPA enforcement approach and priorities. Although it is not an FCPA watershed that announces overhauled enforcement priorities or changes the government’s previously stated positions on some of the more controversial issues, the non-binding, 120-page Guide will undoubtedly be an oft-referenced document for years to come. In DOJ and the SEC Issue Much-Anticipated FCPA Guidance, WilmerHale Partners Roger M. Witten, Kimberly A. Parker, and Jay Holtmeier analyze the key issues addressed in the Guide.
