This summer, the Department of Justice (DOJ) and the Securities Exchange Commission (SEC) revised the agencies’ manual for anti-bribery and anti-corruption compliance. The Resource Guide to the US Foreign Corrupt Practices Act (FCPA) was originally published in 2012. This year’s changes mark the first time the agencies have sought to revise the manual.
The revised Resource Guide contains primarily technical changes, but does provide insight into certain issues where additional guidance has been solicited. The revisions include changes to Chapter 3 of the resource guide concerning Accounting Provisions, as well as Chapter 6 governing Penalties, Sanctions and Remedies. The guidance provided in the Resource Guide is “non-binding,” and informal, however, with the added changes, the guide better aligns with the FCPA statutory language.
Revised FCPA Resource Guide: