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INSIGHT: Under-the-Radar Change Sneaks Into FCPA Guide From DOJ, SEC, Bloomberg Law

July 31, 2020

Morgan Lewis partners Eric Sitarchuk and Matt Miner and associates Jaclyn Whittaker and Amanda Robinson authored a Bloomberg Law article about the US Department of Justice and Securities and Exchange Commission’s updated guide on the Foreign Corrupt Practices Act (FCPA). In the piece, they discuss that by adding the word “accounting” to the “internal controls” provisions, it may signal a shift in FCPA enforcement and create uncertainty in how the SEC and DOJ will differentiate between internal accounting control structures and different aspects of a corporate compliance program.

Read the full Bloomberg Law article >>