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.
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New Guidance Doesn't Mollify FCPA Critics, but Offers Cheat Sheet for Playing Fair
The Litigation Daily
November 14, 2012
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