On 19 November 2013, Mr Ceresney gave the keynote address at the Internal Conference on the Foreign Corrupt Practices Act, outlining four priorities of the SEC in its FCPA enforcement efforts. These include: “(1) the creation of a culture of FCPA compliance among professionals and corporations; (2) international collaboration in combatting bribery; (3) the focus on individual FCPA misconduct; and (4) fostering cooperation with our investigations from companies and individuals,” priority (3) resonating with the comments of Judge Rakoff above.