Despite all the pent-up anticipation, few expected the Justice Department to pack many surprises into its long-awaited guidance on the Foreign Corrupt Practices Act. And sure enough, the DOJ and SEC pretty much regurgitated positions the government has taken in litigation and policy statements all along.
New Guidance Doesn't Mollify FCPA Critics, but Offers Cheat Sheet for Playing Fair
The Litigation Daily
November 14, 2012
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