Clifford Chance

DOJ and SEC Revise FCPA Resource Guide, Incorporating Second Circuit's Ruling in US v. Hoskins

July 17, 2020

On July 3, 2020, the US Department of Justice and Securities and Exchange Commission released a Second Edition of the FCPA Resource Guide, the first substantive update to the Resource Guide since it was originally published in 2012. The Second Edition maintains the structure of the First Edition while incorporating policies and guidance issued in the intervening eight years, addressing significant court decisions in FCPA cases, clarifying issues that have arisen in practice, and providing additional examples and case studies. Since its original publication, the Resource Guide has provided valuable guidance for practitioners, particularly in light of the relatively sparse caselaw interpreting provisions of the FCPA. The Second Edition answers certain lingering questions and also signals the direction DOJ and SEC intend to take with respect to FCPA enforcement.

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