Opinion Release 12-01is significant as it demonstrated not only the evolving nature of best practices under the FCPA but also the DOJ’s thinking on the subject. I think that the DOJ has underlined again the fact intensive nature of the analysis required under the FCPA and how companies, if they used a reasoned approach for a specific FCPA issue or problem, can go a long way towards protecting themselves from potential FCPA liability or exposure. Find out in today's episode.