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Compliance professionals, internal counsel and external counsel face a daunting and increasingly complex landscape when they hear the initial report of potential corruption stemming from their international operations. More recently, this has become the case irrespective both of the location of the potential misconduct and whether it appears on first view to reflect a regulatory or potential criminal issue. The initial decision-making which once might only have contemplated the potential oversight of a very small number of regulatory or enforcement authorities must now include an array of interested parties that can bridge government regulatory, enforcement and criminal bodies located in multiple nations and on multiple continents. This obligatory and expansive thinking is tested as well by the dramatic improvement in cross-border investigative and enforcement cooperation. The Foreign Corrupt Practices Act (FCPA) and anti-bribery space is an excellent place to review this new world order.

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