On November 14, 2012, the DOJ and SEC released long-awaited guidance on the FCPA in the form of a 120-page booklet called “FCPA: A Resource Guide to The Foreign Corrupt Practices Act” (Guide).  The foreword, signed by both Lanny Breuer at the DOJ and Robert Khuzami at the SEC, touts the Guide as “an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.”  The Guide addresses a variety of the hot topics that many in the space have been debating, including the definition of a “foreign official” (which is currently before the Eleventh Circuit); gifts, travel and entertainment expenses; facilitation payments; how successor liability applies in the mergers and acquisitions context; the hallmarks of an effective corporate compliance program; as well as the various tools the DOJ and SEC have at their disposal to resolve cases.  The government also provided a fact sheet about the Guide in which it boasts that there “may [be] no other area of the law where DOJ or SEC has provided the public with as much information about our enforcement approach and priorities.”