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The recent and very prominent media coverage of the Foreign Corrupt Practices Act (FCPA) and money laundering charges brought by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) against employees at Direct Access Partners, a New York broker-dealer, and a senior Venezuelan bank officer highlight an important shift in FCPA and anti-bribery enforcement. The alleged payments made to secure preferential treatment and business in the Venezuelan bond markets open up a new frontier in SEC FCPA enforcement, and, as has been discussed in the FCPA blogosphere, are a vivid illustration of the expanding investigative and audit tools available to the SEC. Indeed, it is safe to conclude that periodic SEC examinations of broker-dealers and other financial services firms will no longer be the province of only audit and financial personnel at these firms. Compliance professionals and internal counsel will need to ensure that they are involved in the process.