"Most of the cases brought to date have involved corporations," said William Steinman, who focuses on FCPA as a partner in the Washington office of Atlanta's Powell Goldstein. But two years ago, he noted, officials from the U.S. Department of Justice and the Securities and Exchange Commission (SEC) indicated during several conferences that actions against individuals would increase.

"They made good on that prediction," he said. "Since May 2005, there have been 22 criminal prosecutions or civil fines and penalties against individuals. A couple have prevailed at trial, but most have not."