The Foreign Corrupt Practices Act (FCPA) prohibits bribery of foreign officials and requires accurate record keeping. It is highly relevant for pharmaceutical companies because they conduct many international clinical trials and operate in countries with national healthcare systems. Enforcement of the FCPA has increased in recent years, with over $1.5 billion in fines in 2010. Companies can minimize risk by voluntarily disclosing issues, establishing rigorous compliance policies, and following OECD anti-bribery guidelines endorsed by 38 countries.