Pepper Hamilton partner Gregory A. Paw is quoted in the December 7, 2012 issue of the Philadelphia Business Journal.
White-collar criminal defense lawyers say the new guidance sheds some light on what constitutes a “foreign official” under the law and how federal regulators assess corporate compliance programs.
Over the past decade, Paw said FCPA activity has exploded with foreign countries passing their own anti-corruption statutes and the United States increasing enforcement, fines and prison times.
Paw said exporters of goods are also at great risk of FCPA violations.
The article, "'Foreign Official' Guidance Provides Some Help, Lawyers Say," is available online with a subscription.