Commenting on the recent FCPA sting in which 22 individuals were arrested, John Davis said “It’s a big splash, but I think the splash is consistent with the cases we’ve seen over the last few years. The message is ‘we’re going to send people to jail for this; don’t do it.’” Davis explained that federal prosecutors, many of whom have a background in drug and mafia cases, are being more proactive in putting together FCPA cases, rather than waiting for voluntary disclosure from companies or whistleblowers. The DOJ also is stepping up its prosecution of individuals. “It’s not just big multi-nationals, but anybody doing business overseas has to comply with this law,” Davis said.