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The recently-announced (and long-awaited) FCPA Guidance is not only explicitly non-binding on government enforcers, but it is also lacking any true “news” concerning the Department of Justice’s (DOJ) and Securities and Exchange Commission’s (SEC) FCPA enforcement positions. That said, the guidance, issued on Nov. 14, does add significant value by collecting the agencies’ prior opinions and providing helpful clarifications and hypothetical case studies for corporate counsel.

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