While the biggest FCPA-related news of 2024 focused on policy changes designed to encourage whistleblowing and voluntary self-disclosure, the DOJ and other enforcement authorities do not just wait for cases to walk in the door. Speaking at the American Conference Institute’s International Conference on the FCPA held in December 2024, regulators revealed how cases are being identified and developed in-house using a variety of tools. This third article in a series on FCPA enforcement in 2024, which includes insights shared with the Anti-Corruption Report by defense counsel, examines two key ways in which the DOJ identifies and builds cases. Part one discussed the role that international cooperation continues to play. The second article looked at the policy changes related to whistleblowers and how they might impact enforcement. See “DOJ’s 2024 Edits to the ECCP: Data Analytics to Find Risks and Measure Effectiveness” (Nov. 20, 2024).