The Department of Justice is trying a new way to catch executives who bribe government officials. It’s going undercover. And general counsel at big and small companies alike should be prepared.

In what’s billed as the first large-scale undercover investigation into violations of the Foreign Corrupt Practices Act, the Justice Department has netted 22 executives, including the general counsel of a company that makes military equipment. They were charged with attempting to pay bribes to win lucrative overseas contracts worth $15 million.

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