The Justice Department has recently stepped up pursuit of foreign bribery cases, initiating more enforcement actions in the last year and a half than during the six years from 2000 to 2005, according to department data. So far this year, it has obtained seven enforcement actions, including indictments, complaints, and deferred prosecution and non-prosecution agreements; last year it secured a record 16, the most since the law went into effect in 1977.
Companies have paid higher penalties during the crackdown, and individual executives have been targeted. Mr. Mendelsohn said the Justice Department has also devoted additional resources to this area and gotten increased cooperation both from foreign authorities under international treaty and companies seeking lighter penalties in return for cooperation. The 2002 Sarbanes-Oxley Act also has imposed new legal requirements on companies to certify internal controls.