Client Alert - Priority Highlights: FCPA Resource Guide 2nd Edition
Compliance professionals around the globe have true grit. They embrace passion, courage and perseverance. Exiger is paying homage to our true G.R.I.T. clients by outlining some important updates from the newly released 2nd Edition of the Resource Guide for the FCPA, which was just jointly published by the DOJ and the SEC and can be found here. While many of the changes are updates to reflect policy guidance published in the time since the 1st Edition (e.g., the recently published update to the Evaluation of Corporate Compliance Programs guidance), there is a new focus on the evolution of compliance programs as a continuous feedback loop, which often impacts the areas represented by the acronym GRIT.