Abstract

http://ssrn.com/abstract=2189072
 
 

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Grading the Foreign Corrupt Practices Act Guidance


Mike Koehler


Southern Illinois University School of Law

December 13, 2012

White Collar Crime Report, 7, 961, December 2012

Abstract:     
This article is a critical analysis of the Foreign Corrupt Practices Act Guidance released by the Department of Justice and Securities and Exchange Commission. Issues discussed in the article include the following: (i) the enforcement agencies' motivations in issuing the Guidance and the fact that it should have been issued years ago; (ii) the utility of the Guidance from an access-of-information perspective and how the Guidance can be used as a measuring stick for future enforcement agency activity; (iii) how the Guidance is an advocacy piece and not a well-balanced portrayal of the FCPA as it is replete with selective information, half-truths, and, worse information that is demonstratively false; (iv) how, despite the Guidance, much about FCPA enforcement remains opaque; and (v) how, despite the Guidance, FCPA reform remains a viable issue.

Number of Pages in PDF File: 8

Keywords: FCPA, Foreign Corrupt Practices Act

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Date posted: December 14, 2012  

Suggested Citation

Koehler, Mike, Grading the Foreign Corrupt Practices Act Guidance (December 13, 2012). White Collar Crime Report, 7, 961, December 2012. Available at SSRN: http://ssrn.com/abstract=2189072

Contact Information

Mike Koehler (Contact Author)
Southern Illinois University School of Law ( email )
1150 Douglas Drive
Carbondale, IL 62901-6804
United States
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