Based on my experience as a U.S. Attorney, I see the new joint Department of Justice (“DOJ”) and Securities Exchange Commission (“SEC”) Resource Guide to the Foreign Corrupt Practices Act (“FCPA”) as a game changer that presents important opportunities for clients with an international footprint. The message from Lanny Breuer at DOJ and Rob Khuzami at the SEC should be loud and clear: it is time to examine and improve your compliance plan because the government wants U.S. businesses to lead the charge in defeating foreign corruption by effective internal efforts — and for those who don’t heed the call, there will be consequences.

FCPA enforcement has exploded in the last ten years from just a handful of enforcement actions in 2004 to more than 70 in 2010, during the time I was U.S. Attorney for Oregon. We’re still considering the implications, but here are some quick take-aways that I see, having worked closely with key authors of the Resource Guide on various enforcement efforts when I was in office...

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