Late last week, the Department of Justice (DOJ) issued a Foreign Corrupt Practices Act (FCPA) Opinion 20-1, its first such opinion in almost six years. In the Opinion, the DOJ advised a U.S.-based investment advisor that the DOJ did not intend to take any enforcement action related to the payment of certain fees to a
Not Very New Wine in an Old Bottle: Recent Revisions to the DOJ FCPA Resource Guide
The Department of Justice (DOJ) just released an updated version of its Resource Guide to the Foreign Corrupt Practices Act. While the new version does not announce any groundbreaking changes, it now includes updates and references to recently issued policies, such as the DOJ’s Corporate Enforcement Policy, Evaluation of Corporate Compliance Programs, and the Corporate