Beyond the FCPA Resource Guide Redlines: What's New and Why It Matters

On July 3, 2020, the US Department of Justice Criminal Division and the Securities and Exchange Commission released the second edition of the US Foreign Corrupt Practices Act Resource Guide (“Resource Guide”). More compilation than revolution, in this second edition, the agencies weave in the foundational FCPA principles with enforcement examples, case law, and policy announcements of the past eight years, since the Resource Guide's initial publication in 2012.

This Mayer Brown Legal Update includes a quick update on what's new in the second edition (with a redline comparison) and then moves beyond the redlines, providing context for some of the key themes in the updated Resource Guide and related practical points that companies can implement now as part of continuous improvements to keep their compliance programs relevant and up to date.