When undertaking a merger or acquisition there are no shortcuts worth taking from the path of compliance with the Foreign Corrupt Practices Act ("FCPA"). Today's increasingly aggressive enforcement climate warrants equally aggressive due diligence by companies seeking to avoid the liabilities inherent in mergers and acquisitions. In early 2009, the new Chair of the Securities and Exchange Commission ("SEC"), Mary Schapiro, announced that FCPA violations "will continue to be dealt with severely by the SEC and other law enforcement agencies."