For every bribe recipient, there is a bribe payer, and the Foreign Corrupt Practices Act focuses on the conduct of the payor, not the recipient. One of the reasons the original round of arrests in the FIFA corruption scandal was focused solely on individuals was that they were the ones alleged to have received the bribes. However, that direction may be shifting. A recent report says that the Justice Department has begun to look at the “role of multinational sponsors, broadcasters, and banks” in facilitating the corruption.
