Appendices

• Author: Robert W. Tarun
• Pages: 465-466

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

465