For decades, it has irked those subject to the Foreign Corrupt Practices Act (FCPA) that those who demanded payments appeared to escape the crushing consequences. The FCPA was first enacted by Congress in 1977 to combat the wide-ranging corruption that was seen as unsettling free-markets and hindering democratic stability. Foreign Corrupt Practices Act of 1977, 15 U.S.C. §§78dd-1, et seq; see also U.S. Department of Justice and Securities and Exchange Commission, A Resource Guide to the U.S. Foreign Corrupt Practices Act (Second Edition). The law prohibits U.S. companies, persons and issuers as well as foreign persons and businesses acting within the U.S. territory from making or promising anything of value to foreign officials to obtain or retain business or an improper business advantage. Yet the FCPA has one significant limiting factor: it only reaches the supply side of bribes to foreign officials.