Here’s a tip about how U.S. corporate executives can avoid violating America’s anti-foreign bribery law: Buying a foreign official a latte won’t likely draw scrutiny, but skip the trip for two to Paris.
Ending months of speculation among corporate officials and white-collar defense attorneys, the U.S. Justice Department and U.S. Securities and Exchange Commission last week published a much anticipated guide that attempts to clarify key provisions of the Foreign Corrupt Practices Act. The 120-page memo is the product of a year of work for senior DOJ lawyers and SEC officials who set out to craft a comprehensive catalogue of court rulings, hypothetical scenarios and enforcement practices in the criminal and civil arena.
