The origins of a Foreign Corrupt Practices Act enforcement action can be numerous and varied.
As explored in this prior post, 2022 corporate enforcement actions originated from voluntary disclosures, foreign law enforcement investigations, and media reporting.
Other origins of FCPA enforcement actions have included whistleblower or competitor complaints and unrelated government investigations.
FCPA enforcement actions can also originate in other interesting and unique ways. The 2001-2002 enforcement action against David Kay and Douglas Murphy is an instructive example.