This article was reprinted with permission from FCPA Professor
I am pleased to share a download link (here) to
my article "Grading The Foreign Corrupt Practices Act Guidance" recently
published in Bloomberg / BNA's White Collar Crime Report.
The article abstract is as follows.
This article is a critical analysis of the Foreign Corrupt
Practices Act Guidance released by the Department of Justice and Securities and
Exchange Commission. Issues discussed in the article include the following: (i)
the enforcement agencies' motivations in issuing the Guidance and the fact that
it should have been issued years ago; (ii) the utility of the Guidance from an
access-of-information perspective and how the Guidance can be used as a
measuring stick for future enforcement agency activity; (iii) how the Guidance
is an advocacy piece and not a well-balanced portrayal of the FCPA as
it is replete with selective information, half-truths, and, worse information
that is demonstratively false; (iv) how, despite the Guidance, much about
FCPA enforcement remains opaque; and (v) how, despite the Guidance, FCPA
reform remains a viable issue.
Read more articles on the FCPA by Mike Koehler at FCPA Professor.
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