The Department of Justice (DOJ) continues its vigilant pursuit of violations of the Foreign Corrupt Practices Act (FCPA) by both corporations and individuals. A recent case in California indicates an aggressive new policy by the DOJ to use the Travel Act (18 U.S.C. § 1952), in addition to the FCPA (15 U.S.C. § 78dd-2), to prosecute alleged foreign bribery. The FCPA has been widely used to prosecute bribery of foreign public officials, but use of the Travel Act expands the scope of bribery prosecutions into the private business context. This is a noteworthy development for any company that conducts foreign business.