FCPA Resource Guide

 In Compliance, FCPA

This highly useful 150-page resource guide published in late 2012 is the fruit of cooperation between the Department of Justice and the Securities Exchange Commission, with contributions from the departments of Commerce and State as well. Among other things, the guide addresses the ABCs of the FCPA. This includes must-know basics such as: (1) the scope of the FCPA’s anti-bribery and financial rules; (2) how to recognize a “foreign official” on the street; (3) how to distinguish”proper” and “improper” gifts, travel and entertainment expense (hint: your customer can sign that contract just as well with a “Bic” as she can with a “Montblanc”); (4) the double-black-diamond slope of “facilitation” payments; (5) the FCPA and M&A; (6) common characteristics of effective compliance programs; and, as if you needed any more motivation to get busy, (6) the menu of criminal and civil torments that face FCPA violators. Maybe it would be a good idea to add the FCPA Resource Guide to your corporate overseas travel checklist, along with the travel visa, vaccinations, and no-iron blazer?