For federal prosecutors, the Foreign Corrupt Practices Act has become a sleeper hit—but no Hollywood types will be celebrating when this once-dormant bribery statute makes a September Tinseltown debut.

The F.C.P.A., after decades of being ignored, is ensnaring an increasing array of companies, from energy exploration and telecom concerns to medical-device makers and freight forwarders, for alleged kickbacks to government officials around the globe. Now, even Hollywood is in prosecutors' crosshairs for bribery along the film-festival circuit—a case that could mark the beginning of the industry's own serious Syriana-style woes.

The Department of Justice has accused critically acclaimed Rescue Dawn producer Gerald Green and his wife Patricia of attempting to pay more than $900,000 in bribes to a high-level Thai government official in the hope of gaining the concession to run an international film festival in Bangkok. The Greens have plead not guilty on all charges.
    
While the D.O.J. declined to comment on the case, its deterrent effect is not lost on Mark Mendelsohn, deputy chief of the agency's fraud section. "As we bring cases in industries that were not previously a focus of F.C.P.A. enforcement actions, that does have the effect of causing a lot of players in that industry to wake up and pay attention," he says.

The case has already caused fallout in Thailand, which has begun its own investigation into the bribery allegation. The Thai official believed to be at the center of the controversy, Juthamas Siriwan, has discontinued her run for a seat in parliament and publicly threatened to sue the Justice Department for involving her in what she has called a groundless accusation.

For Hollywood, the concern is that recent F.C.P.A. cases in other industries have tended to ensnare other companies using, for instance, the same government go-betweens or the same methods to curry favor abroad. Whether this will be the case for the film industry remains to be seen, but the proximity of the film-festival bribery case comes uncomfortably soon after two other unwelcome revelations.

The trial of celebrity private investigator Anthony Pellicano recently uncovered bribery of government officials to further the aims of some Hollywood power brokers. Also, last year, the Los Angeles Times unearthed budget documents from the 2005 mega-flop Sahara that list $237,386 for courtesy payments, gratuities and local bribes while filming in Morocco.

Nobody involved with Sahara has been charged with a F.C.P.A. violation. And as long as they are correctly accounted for and not part of "a slush fund," the act exempts certain small payments to expedite routine services, says Danforth Newcomb, a well-known F.C.P.A. expert with the law firm of Shearman & Sterling. The question that comes up, the lawyer says, is "when does it stop being a facilitating payment, which implies a one-off situation, and instead becomes a method of doing business. That question applies equally to the film industry."

Bill Lindstrom, C.E.O. of the Association of Film Commissioners International, says production companies have often paid to obtain "extra services," to assure that what is promised by officials is actually provided, and to "prevent something bad from happening on set."

But last month his organization grew concerned enough about these payments that it decided to offer a new seminar at its Locations Trade Show. The title: "Greasing Palms on Location: What You Need to Know About the Foreign Corrupt Practices Act."

Hollywood is right to pay attention, as both the aggressiveness of prosecutors and the cost of violations have been rising.

According to data compiled by Shearman & Sterling, there are currently investigations involving more than 80 companies; in 2003, there were fewer than 10. Meanwhile, last year the oil-services company Baker Hughes paid a record $44 million to settle claims that it bribed officials in Kazakhstan, Nigeria, Angola, Indonesia, Russia and Uzbekistan to obtain oil- and gas-related contracts.

Also, prosecutors hoping to focus corporate managers' attention on the problem have increasingly gone after them individually. For instance, last October, David Kay and Douglas Murphy, two former executives with American Rice, received 37- and 63-month sentences, respectively, for their roles in a scheme to avoid $1.5 million in Haitian import duties and taxes.

Corruption is a massive problem, with the World Bank estimating that more than $1 trillion in governmental bribes are paid every year worldwide.

Still, not too long ago companies had little to fear if they used bribes to gain concessions. Enacted in 1977, following government studies that pointed to widespread corporate bribery, the F.C.P.A. was seldom enforced. And even when it was, prosecutors had an uphill battle gaining evidence, because many other countries turned a blind eye. Until 1999, foreign bribes were tax-deductible in both Germany and France, notes Fred Miller, co-leader of global F.C.P.A. investigations and forensic services at PricewaterhouseCoopers, adding "for a long time the U.S. rule was the only game in town."

But this is no longer the case. Domestically, the Department of Justice and the S.E.C. have made F.C.P.A. enforcement a high priority. For instance, over the last year and a half, the D.O.J. has repurposed three prosecutor slots to handle only F.C.P.A. investigations, while the F.B.I. has created eight dedicated F.C.P.A. agent positions in its Washington field office. Before, they had non

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One symbol of greater international cooperation took place last November in Rome at the 10th anniversary of the Organization of Economic Co-operation and Development's signing of antibribery statutes. For the first time, prosecutors from the signatory countries, about 70 law-enforcement officials in all, came together to share their experiences and discuss their cases. The group will now meet once a year.

All of this greater law-enforcement focus on corruption has come as companies are uncovering more of their own F.C.P.A. violations—often revealed due to the greater financial controls required by the Sarbanes-Oxley Act or searched for during the scrubbing that takes place when there is a merger or acquisition. Federal officials have helped encourage self-reporting of these violations by giving companies steep reductions in fines for cooperation.

There is no indication that Hollywood executives will soon be banging down prosecutors' doors. But another F.C.P.A. trend—that of irritated competitors spilling allegations to prosecutors—may give some in the industry pause. Either way, Miller says filmmaking is just the type of business that might end up with F.C.P.A. issues to atone for.

"If you think about the film industry, they go on location and don't have a lot of time," he says. "If you want to shut down traffic in a town, how does that happen? Could the industry be subject to these bribery rules and might they run into some issues? You bet."

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