American companies are being bombarded with warnings about the federal Foreign Corrupt Practices Act (FCPA), and the warnings have become increasingly ominous.
In November 2009, the head of the Department of Justice’s (DOJ) Criminal Division specifically advised pharmaceutical companies that prosecutors are focusing on their industry. Commentators previously suggested that the DOJ treats FCPA concerns as second only to national security concerns, but in February 2010, a prosecutor who supervised FCPA matters at the DOJ stated at a conference that corruption is a national security issue.
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