BY: EVELYN M. SUAREZ & J. FORBES THOMPSON
On November 14, 2012, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) released the much anticipated guidance on the Foreign Corrupt Practices Act (“FCPA”) entitled A Resource Guide to the U.S. Foreign Corrupt Practices Act (“Guide”). The Guide was created at least in part to respond to the OECD criticism that U.S. anti-corruption efforts could be improved by providing a consolidated presentation of public information on the application of the FCPA and enhancing awareness by small and medium-sized companies about the prevention and detection of foreign bribery.