The Department of Justice recently issued its eighth public declination in a Foreign Corrupt Practices Act case and the first under its FCPA Corporate Enforcement Policy—an indication that the policy is alive and well. But the case also brings with it a clear warning: The anti-bribery provisions are not the only way to trip over the FCPA.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...