Every time you turn around, the Justice Department or SEC announces a new round of charges and settlements against individuals and entities under the Foreign Corrupt Practices Act (FCPA). Historically, the government has focused FCPA enforcement efforts on persons or entities within the U.S., or on foreign persons or entities that commit unlawful acts within our borders.

But, more recently, the government has employed conspiracy or aiding and abetting theories to reach acts of foreign bribery not previously thought to be within U.S. law enforcement’s reach. This article examines recent charges and settlements suggesting a new approach by federal authorities to foreign bribery. Read more