In the past five years, the DOJ has investigated more international bribery cases than in the prior 20. More and more multinational corporations are beefing up their international compliance programs, as well as self-reporting to the DOJ any potential irregularities that they do find in hopes of lenience. The man behind the curtain who is making corporate counsel tremble with fear is Mendelsohn. He is responsible for all criminal investigations and prosecutions under the Foreign Corrupt Practices Act (FCPA), as well as principal policy responsibilities relating to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Those who know him say that there is one way to stay on Mendelsohn’s good side: don’t bribe. Mendelsohn himself is quick to point out that the DOJ has yet to bring charges against any companies that have had a “meaningful compliance program” already in place.