Six years ago today, on November 14, 2012, the DOJ and SEC released the FCPA Guidance. The guidance generated a substantial amount of buzz, but the festive coverage soon subsidized as the guidance turned 1, 2, 3, 4, 5 and now 6 years old.
Yet, on this sixth anniversary of the FCPA Guidance, it is useful to take a look back.
As highlighted in this prior post, the 2012 FCPA guidance was a long-time coming to say the least.