In this article, Pravin Rao, Lee Stein, Markus Funk, Bridget Minder, Caryn Trombino, and Amy Chang analyzed the DOJ and SEC's new guidance on the Foreign Corrupt Practices Act (FCPA).  The authors discussed that the long-anticipated guidance provided helpful clarifications and hypothetical case studies for corporate counsel, and yet is not binding on courts or even the agencies themselves.  The article cautioned that corporate counsel remain cognizant that the guidance may change, perhaps even dramatically.