The FCPA Guidance After One Year: The Impact on Compliance and Practice

It has now been a year since 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 provided user-friendly insight into how the government approaches FCPA enforcement, and set forth a number of factors companies should consider in evaluating their anti-corruption compliance programs and procedures. The FCPA guidance addressed a number of critical compliance concerns, including among others the use of third-party intermediaries, and the current state of parent/subsidiary and successor liability. It also created a one-stop resource for compliance personnel and affected business managers. The webcast will offer a practical and informed review of how the guidance has impacted FCPA practice generally, and more specifically how the guidance has affected compliance operations and the interaction of compliance professionals with both their business units and external counsel.