Just in time for the season of giving, the Department of Justice and the Securities and Exchange Commission have doled out a much-anticipated gift of their own: a resource guide to the Foreign Corrupt Practice Act.
By essentially unifying into a single document what previously existed as a piecemeal collection of informal opinions and case law, the 120-page guide represents the most comprehensive analysis produced in the law's 35-year history on how the government enforces the FCPA and how it interprets some of its more clouded components.
While the guidance helps clear up some gray areas of the law, it stops well ...