Last year saw not only a continuing growth in the number of FCPA cases and of the fines and other penalties involved, but also a significant expansion of the tactics authorities employ in corruption investigations.

“When you look prospectively into 2011 and beyond, you're going to see a lot more 'Catch-22' type cases,” says Perkins Coie partner Markus Funk. “The DOJ will be out there doing undercover investigations, using tips to try to develop sources and investigate cases. FBI agents are not used to just sitting around, waiting for the phone to ring.”

Even so, the phone may start ringing more often. The Dodd-Frank Act, passed in July 2010, includes provisions that would give FCPA whistleblowers 10 to 30 percent of penalty fines ultimately imposed. If you have any doubt what looms on the horizon, just take a second to Google “FCPA Whistleblower” and count the plaintiffs firms queuing up.