ase process, it has declared its decision to follow the guidance announced through DOJ’s FCPA Opinion Release Procedure. US. Sec. and Exchange Comm., SEC Release No. 34-17099 (Aug. 29, 1980), available at hetp:// www.sec.gov/news/digest/1980/dig082980.pdf. SEC Release No. 34- 17099 stated that, to encourage issuer