This guide is intended to provide information for businesses and individuals regarding the US. Foreign Corrupt Practices Act (FCPA). The guide has been prepared by the staff of the Criminal Division of the U.S. Department of Justice and the Enforcement Division of the US. Securities and Exchange Commission. It is non-binding, informal, and summary in nature, and the information contained herein does not constitute rules or regulations. As such, it is not intended to, does not, and may not be relied upon to create any rights, substantive or procedural, that are enforceable at law by any party, in any criminal, civil, or administrative matter. It is not intended to substitute for the advice of legal counsel on specific issues related to the FCPA. It does not in any way limit the enforcement intentions or litigating positions of the U.S. Department of Justice, the US. Securities and Exchange Commission, or any other US. government agency. Companies or individuals seeking an opinion concerning specific prospective conduct are encouraged to use the US. Department of Justice’s opinion procedure discussed in Chapter 9 of this guide. This guide is United States Government property. It is available to the public free of charge online at www,justice.gov/ criminal/fraud/fepa and www.sec.gov/spotlight/fcpa.shtml. HOUSE_OVERSIGHT_022495