The U.S. Securities and Exchange Commission (“SEC”) on May 20, 2015 announced a settlement with global resources company BHP Billiton over allegations that BHP Billiton violated the Foreign Corrupt Practices Act (“FCPA”) by providing luxury travel packages to foreign government officials and their spouses at the 2008 Beijing Olympic Games. The settlement, imposed through a

On Nov. 14, 2012, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) jointly issued A Resource Guide to the U.S. Foreign Corrupt Practices Act (the “Guide”), available at http://www.justice.gov/iso/opa/resources/29520121114101438198031.pdf. The 120-page Guide provides a detailed analysis of the FCPA from the perspective of the government agencies charged with enforcing it.