Confusing “Guidance” from DOJ and SEC on Third Party Liability
The FCPA Guidance is a terrific contribution to FCPA law and policy. I have the utmost respect and admiration for the DOJ and SEC professionals who enforce this law. They are true public servants. A testament to the importance of the FCPA Guidance is the absence of any meaningful or persuasive criticism of the FCPA Guidance. Of course, the FCPA Paparazzi will try and strike...