FIFA seems to have changed its tune since the U.S. Justice Department announced the indictment of 14 high-ranking officials in May. FIFA has hired the law firm of Quinn Emanuel Urquhart & Sullivan to engage in, as reported in the Wall Street Journal, “the most far-reaching and thorough review in FIFA’s 111-year history” around allegations of bribery and corruption. A FIFA official was quoted as saying, “An essential component of our efforts is an internal investigation conducted by external counsel. This work is ongoing and therefore we will not comment further.”

Why did FIFA have this change of heart? Clearly it was the fallout from the May indictments. If FIFA had continued to bury its head in the sand (or as it did with the prior internal investigation, the Garcia Report, bury it), that could have led to the United States indicting FIFA itself. If FIFA itself was indicted, that could result in the freezing of its assets.

The U.S. government has demonstrated that it will aggressively pursue internationally housed ill-gotten gains with its attempt to seize the assets generated by the alleged bribery around the Uzbekistan telecom corruption scandal. FIFA’s significant assets in Switzerland could have been attached and seized.

How will this investigation be different from the Garcia investigation? First is that FIFA’s executive committee is now subject to the investigation and committee members will have to “sit for interviews.” Next, the investigation will review the bidding process for not only Russia’s winning 2018 bid and Qatar’s winning 2022 bid, but also the decision to award the 2010 World Cup to South Africa.

The investigators will have access to all “electronic communication, including e-mail and text messages, that exist on FIFA’s computer servers, personal e-mail accounts of current and former executive committee members and even computer servers controlled by” the various regional soccer federations, such as CONCACAF. The investigation may have both U.S. government and Swiss government assistance to look into personal bank accounts of FIFA executives.

All of this sounds like FIFA may have finally seen the light, and further, may let the light shine into what previously could be called (at best) an opaque process.