Category: General

Dancing Around the Edges:  A Journey in the FCPA Guidance

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...