Dancing Around the Edges: A Journey in the FCPA Guidance
I am really enjoying reading and re-reading the FCPA Guidance. It is a fascinating document, well written and chock full of salient points, messages, explicit and implicit. For me, the most important issues are those that are in the so-called “gray area.” Some of the hypotheticals and the anonymous declinations are easy calls – after reading them, I am positive of the answer. The descriptions...