Insights
Client Alert
Quarterly FCPA Report: Third Quarter 2012
November 21, 2012
BY GLOBAL COMPLIANCE & DISPUTES PRACTICE GROUP
The DOJs and SECs activities in the third quarter signal that the enforcement authorities require continued diligence from U.S. companies to ensure their monitoring programs are sufficient to identify and correct potentially improper actions. In the fourth quarter, the DOJ also released its long-awaited guidance on several contested provisions of the FCPA.