Ask a corporate executive to define the Foreign Corrupt Practices Act, and most will state the obvious: it outlaws bribery to foreign officials when doing business overseas.

In reality, thanks to some uncompromising provisions of the FCPA, mundane books-and-records mistakes are much more likely to put a company in the crosshairs of an enforcement action.

“These cases usually have nothing to do with anything foreign or corrupt,” says Matt Morley, head of the corporate practice at law firm Fried, Frank, Harris, Shriver & Jacobson. “It’s just that books and records were not kept properly, that the accounting is not up to ...