John Davis discusses the government charges against BAE Systems. Although not an FCPA case, according to Davis, the charges almost sound like FCPA violations. "It is interesting in the sense that their description of the facts effectively enumerates what could be an FCPA violation, but they’re not charging them with that," he said. Davis believes there could be several reasons the Justice Department did not allege that BAE paid bribes to foreign officials. He said the DOJ may have been restricted by a statute of limitations or it may have feared that BAE could face debarment if it admitted to illicit payments. "Debarment would be a problem for [the Department of Defense] given the size of BAE and what they do for them," he said. Going forward, Davis said that other legal action against BAE is a possibility, including prosecutions of BAE employees and shareholder suits.