id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-2875	Epner, Justin	Settling on an Interpretation of “Instrumentality” in the FCPA	2014	52	.pdf	application/pdf	17642	887	53	Yet, despite its status as a powerful regulator of business conduct, the statute's key element is shrouded in mystery and only recently drew the attention of a federal circuit court for the first time.3 The explosion in FCPA enforcement since the second George W. Bush administration has transformed the FCPA from an afterthought to a crown-jewel practice for major law firms, 4 as well as the subject of substantial media scrutiny.' And, more significantly, the FCPA anti-bribery provisions grant the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) authority to bring criminal or civil charges against corporations and individuals who bribe a foreign official in order to obtain a business advantage.8 From 1977 until the early 2000s, DOJ and SEC brought just a few cases per year between them.9 However, during President George W. Bush's second term, Alice Fisher, head of DOJ's Criminal Division, established a unit devoted exclusively to FCPA enforcement.'	cache/cblr-2875.pdf	txt/cblr-2875.txt