For years the Department of Justice has served as the self-appointed sheriff in the global fight against business corruption using as its weapon the Foreign Corrupt Practices Act (“FCPA”), the first transnational anticorruption and antibribery legislation.

Many FCPA critics have claimed the statute is another attempt by the U.S. to impart its beliefs and values on the global business world as U.S. regulators have levied billions of dollars in fines, penalties and disgorgement of profits through its investigations and punishments of U.S. and non-U.S. companies.