This could be an especially tough enforcement year under the Foreign Corrupt Practices Act for corporate gatekeepers, such as general counsel, chief compliance officers and chief financial officers, according to Shearman & Sterling partner Philip Urofsky.

In an interview Wednesday about his law firm’s just released 2019 FCPA Digest, Urofsky said he expects law enforcement to focus their efforts not only on individuals in 2019, but on corporate gatekeepers in particular.