On November 12, 2009, Lanny Breuer, Assistant Attorney General for the Criminal Division of the Department of Justice, warned that in the “months and years ahead,” the Department of Justice will focus on “the application of the Foreign Corrupt Practices Act (or "FCPA?) to the pharmaceutical industry.” Previous FCPA enforcement actions also have focused on medical device companies. Given this DOJ initiative, life sciences companies should actively review and reinvigorate their FCPA compliance efforts.