It’s safe to say that the intense effort to tackle foreign bribery has been the single most striking corporate criminal enforcement trend over the past several years. The numbers from the Justice Department’s fraud section, which prosecutes Foreign Corrupt Practices Act (FCPA) cases, tell an unmistakable story.

In 2004, the Department of Justice (DOJ) booked just two FCPA cases, netting a total of $11.3 million in criminal penalties. It’s been a steep climb ever since.