Homer Moyer comments on the recent FCPA sting in which the government arrested 21 individuals on corruption charges. Homer Moyer says the case is perhaps the starkest example yet of the government’s targeting individuals, rather than companies, for alleged FCPA violations. “It used to be you’d go after the companies first, then follow up with individuals if the behavior was egregious,” says Moyer. “But the government is now targeting individuals, presumably so they can get some cooperation in building a case against larger entities.”