• Here's a ton of guidance from the SEC and DOJ on Foreign Corrupt Practices investigations, the new boom area for DC practitioners, and principal headache of the multinational.  JPMorgan is the latest firm to be ensnared; my sense is that financial firms have generally had a better run than most when it comes to avoiding prosecution.  HT
• And here's ISS's new approach to 2013 votes.  It isn't going to go entirely for labelling the pledging of stock to be a problematic company pay practice; it is also going to wait before recommending a vote against boards that ignore shareholder proposals that pass with a majority vote. But both look like they're in the offing.  HT

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