Nov. 28 Webcast: Breaking Down the FCPA Guidance — Key Takeaways and Grey Areas

On November 14, the DOJ and SEC released their long-awaited guidance on the FCPA, “A Resource Guide to the U.S. Foreign Corrupt Practices Act.” The guidance provides some insight into how the government approaches FCPA enforcement, and sets forth a number of factors companies should consider in evaluating their anti-corruption compliance. The new FCPA guidance addresses a number of areas, including the use of third-party intermediaries; the treatment of “facilitation” payments; risk factors associated with gifts, travel, and entertainment expenses; and the current state of parent/subsidiary and successor liability; among others. The webcast will review many of these key areas, and will provide an analysis of the enforcement declinations described in the guidance to identify which characteristics appear to be the most important to the government in deciding not to bring an action. The program will review what questions remain unaddressed by the guidance, and highlight what areas companies should focus on to ensure compliance with all aspects of the FCPA. Please join Robertson Park, Timothy Peterson and Greg Esslinger as they address these issues and your questions in a free, one-hour webcast.