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.” As discussed in depth on Compliance Week, the guidance provides insight into how the government approaches FCPA enforcement, and sets forth a number of factors companies should consider in evaluating their anti-corruption compliance.

Today, just two weeks after the guidance was issued, former DOJ and SEC officials, and other leaders in the anti-corruption field, joined me as panelists for an excellent webcast entitled, "Breaking Down the FCPA Guidance — Key Takeaways and Grey Areas." The panel examined the guidance chapter by chapter, explaining key areas including

  • the use of third-party intermediaries; 
  • the treatment of “facilitation” payments; 
  • risk factors associated with gifts, travel, and entertainment expenses; 
  • the current state of parent/subsidiary and successor liability; 
  • enforcement declinations;
  • grey areas that remain unaddressed by the guidance; and 
  • areas companies should focus on to ensure compliance with the FCPA.

The panel for this webcast was Robertson Park, Partner, Murphy & McGonigle; Timothy Peterson, Partner, Murphy & McGonigle; and Greg Esslinger, Senior Managing Director with FTI Consulting. The archived version of the webcast can be viewed below.

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