A Major Due-Diligence Barrier To Overseas M&A Gets Tempered

A 2008 advisory opinion from the DOJ, called the Halliburton opinion, required such extensive, expensive and time-consuming pre-merger anti-corruption due diligence that it prevented some otherwise viable mergers from taking place, especially in emerging markets. A new DOJ/SEC Foreign Corrupt Practices Act resource guide appears to signal a retreat from those extreme requirements.