Some Additional Comments on the FCPA

摘要

This article highlights the impact of the OECD's "Good Practice Guidance," the impact of the UK Bribery Act of 2010, including the soon-to-be promulgated guidelines as to what constitutes "adequate procedures" under that Act, and the DOJ's FCPA Opinion Procedure. The goal of this article is to provide information that will enableclients to develop procedures that will enable them to be in compliance with the anti-bribery provisions of the FCPA and the UK Bribery Act of 2010.