A crescendo of enforcement actions under the Foreign Corrupt Practices Act (FCPA) over the last two years has produced more headlines and more corporate anxiety than ever before, writes Homer Moyer. With this unprecedented activity, addressing a number of old and new issues relating to how this law is administered and enforced could advance the public policy objective of preventing bribery of foreign government officials that underlies this 28-year-old statute. Changes in FCPA enforcement leadership—just completed at the Department of Justice (DOJ) and upcoming at the SEC—are appropriate occasions for such a review.

Reprinted with Permission from the May 23, 2005 edition of the National Law Journal. © 2005 ALM Properties, Inc. All rights reserved. Further duplication without permission is prohibited.