Almost no FCPA case begins with an executive handing cash to a minister. This article explains where enforcement actions actually come from: third-party intermediaries who were never diligenced, hospitality that drifted from reasonable to lavish, charitable contributions to entities connected to decisionmakers, the hiring of officials' relatives, and acquisitions that imported a target's existing conduct. It works the statute's two halves, explaining why the books-and-records and internal controls provisions apply only to issuers but generate more enforcement than the anti-bribery provisions do, and why the absence of a materiality threshold makes them so powerful. It covers the elements of the bribery offense including the contested definition of foreign official after Esquenazi, the narrow facilitating payments exception and why sophisticated companies have abandoned it, the two affirmative defenses, and the jurisdictional reach that Hoskins limited. It then turns to practice: the voluntary self-disclosure calculus and what declination with disgorgement actually buys, monitorships, successor liability in mergers and the pre-closing diligence that manages it, and the global regime including the UK Bribery Act's failure-to-prevent offense with its adequate procedures defense. It closes with the enforcement-policy volatility that makes standing compliance more valuable than reactive compliance.