The DOJ and SEC’s recent actions against financial services entities such as Direct Access Partners may be a harbinger of more scrutiny to come.  The increased focus on the financial services industry, along with the government’s aggressive expansion of its theories of parental liability for actions taken by subsidiaries and other business units (as revealed in the recent Ralph Lauren enforcement action), has special relevance both to standalone private equity firms and to investment banks and similar entities with private equity arms or subsidiaries.  Parent companies may be facing greater exposure than ever before for the misconduct of their subsidiaries, and thus face a greater risk of being the subject of the next enforcement action.  In a guest article, Seth C. Farber and Riche T. McKnight, partners at Winston & Strawn LLP, and Ryan D. Fahey, an associate at Winston & Strawn LLP, review relevant enforcement actions under the FCPA’s anti-bribery, books and records and internal control provisions, and outline critical steps that private equity firms and investment banks with private equity arms can take to reduce their overall FCPA exposure.  See also “FCPA Charges against Broker-Dealer Stemming From Routine SEC Examination Is ‘Wake-Up Call’ to the Financial Services Industry” (May 15, 2013); “SEC’s NPA with Ralph Lauren, the Agency’s First Ever, Modifies the M&A Due Diligence Requirements Traditionally Included in DOJ DPAs, and Outlines Specific Actions That Constitute Effective Self-Reporting” (May 1, 2013).