On November 14th, the SEC and the Department of Justice released A Resource Guide to the U.S. Foreign Corrupt Practices Act. The guide provides an analysis of the Act and examines the SEC and Justice Department approach to FCPA enforcement. The guide addresses a wide variety of topics including who and what is covered by the FCPA's anti-bribery and accounting provisions; the definition of a "foreign official;" what constitute proper and improper gifts, travel, and entertainment expenses; facilitating payments; successor liability; the hallmarks of an effective corporate compliance program; and the different types of civil and criminal resolutions available in the FCPA context. Joint Press Release.