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The Wiley Rein Pocket Part to the FCPA Resource Guide

March 2016

By Gregory M. Williams, Daniel B. Pickard, Ralph J. Caccia, and Richard W. Smith

On March 10, Wiley Rein’s FCPA Group released a unique publication. In November 2012, the Department of Justice and Securities and Exchange Commission published the Resource Guide to the U.S. Foreign Corrupt Practices Act (the Guide), addressing a broad range of topics regarding the interpretation and enforcement of the FCPA. Given the paucity of judicial precedent under the FCPA, the government’s pronouncements regarding the meaning of the anti-corruption law carry substantial weight.  U.S. officials, however, have announced that they do not intend to update or supplement the Guide.  Wiley Rein, therefore, has created a “Pocket Part” to address subsequent FCPA developments.

The 60-page Pocket Part will not summarize the factual details of every FCPA matter. Rather, it selectively addresses the key FCPA settled actions and other related developments that either underscore the central lessons of the Guide or illustrate developing trends in FCPA enforcement. The document is intended to sit on your shelf next to Guide as a resource for counsel and compliance professionals confronting challenging FCPA compliance and investigatory questions.

An excerpt of the Pocket Part can be read here.