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In recent years, there has been a significant uptick in the number of prosecutions of individuals under the Foreign Corrupt Practices Act (FCPA). From 2008 through May 2013, the Department of Justice (DOJ) charged over 80 individuals with violating the FCPA, over twice the number that was prosecuted in the 10 preceding years.1 The increase has been viewed within the DOJ as a significant component of FCPA enforcement. Lanny Breuer, the Assistant Attorney General for the DOJ's Criminal Division who oversaw this rise in FCPA enforcement, remarked last year that the Criminal Division's single most important achievement during his tenure was that "corporate executives now actually believe—for good reason—that if they participate in a scheme to improperly influence a foreign official, they face the very real prospect of going to prison."2

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