John Davis comments on the tactics used in a January FCPA sting in which 22 executives were arrested. "A lot of the guys who do FCPA stuff, including [DOJ Fraud Section Deputy Chief] Mendelsohn and some of his deputies, have done either drug or Mafia stuff in the past," says Davis. "It’s not surprising that they’re putting their heads together and saying, ‘Hmmm, that worked there, let’s try it here.’" The article notes that the sting is evidence that no business is off the radar for FCPA crimes, and may indicate the current direction of the enforcement spotlight. "As is true in a lot of these cases, they’re looking at an industry," Davis says. "This has been one of the trends the last couple of years. They’ve looked at the oil field industry, they’ve done blanket-type investigations in the pharmaceutical industry. Now they’re looking at the [small arms] industry." Regarding the government’s use of a cooperating witness in the sting, Davis says, "Most of these cases involve third parties. It’s another reminder that companies really need to watch out who they’re doing business with."