Appendices

AuthorRobert W. Tarun
Pages465-466
Appendices
Appendix 1. United States Foreign Corrupt Practices Act (Nov. 10, 1998) 467
Appendix 2. Organization of Economic Cooperation and Development (OECD)
Convention on Combating Bribery of Foreign Public Officials in
International Business Transactions (1997) 485
Appendix 3. U.K. Bribery Act 2010 and Explanatory Notes (2010) 491
Appendix 4. U.S. Department of Justice Lay-Person’s Guide to FCPA 523
Appendix 5. DOJ FCPA Opinion Releases Index 531
Appendix 6. FCPA Acquisition Due Diligence Checklist 541
Appendix 7. American College of Trial Lawyers’ Recommended Practices for Companies
and Their Counsel in Conducting Internal Investigations (February 2008) 545
Appendix 8. Title 9, Chapter 9-28.000 Principles of Federal Prosecution of
Business Organizations (U.S. Department of Justice) 581
Appendix 9. Morford Memorandum on Monitors 603
Appendix 10. Report of Investigation Pursuant to Section 21(a) of the Securities
Exchange Act of 1934 and Commission Statement on the Relationship
of Cooperation to Agency Enforcement Decisions (Exchange Act Release
No. 44969, Accounting and Auditing Enforcement Release No. 1470,
October 23, 2001) (“Cooperation Statement”) (Seaboard Opinion) 611
Appendix 11. United States Sentencing Guidelines: Effective Compliance and
Ethics Programs 617
Appendix 12. SEC Policy Statement Concerning Cooperation by Individuals in
Its Investigations and Related Enforcement Actions 623
Appendix 13. A Proposal for a United States Department of Justice Foreign Corrupt Practices
Act Leniency Policy, (Robert W. Tarun and Peter P. Tomczak), excerpted from a
law review first published in 47 Am. Crim. L. Rev 153 (2010) 627
Appendix 14. Final Whistleblower Rules Pursuant to Section 922 of the Dodd-Frank
Wall Street Reform and Consumer Protection Act (May 25, 2011) 635
Appendix 15. U.K. Bribery Act Guidance (March 31, 2011) 659
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