The Foreign Corrupt Practices Act (“FCPA”) generally prohibits the bribery, whether direct or indirect, of foreign officials. The FCPA also requires publicly traded companies to maintain accurate books and records and to have a sys-tem of internal controls su cient to provide reason-able assurances that transactions are executed and assets are accounted for in accordance with management’s authorization and recorded as necessary to permit the preparation of nancial statements in conformity with generally accepted accounting principles. Enforcement of the FCPA is the joint responsibility of the SEC and the DOJ.