Last week, The Wall St. Journal, The New York Times and other news outlets reported that the U.S. Securities and Exchange Commission (“SEC”) has launched an investigation into possible violations of the Foreign Corrupt Practices Act (“FCPA”) by financial institutions that have had dealings with sovereign wealth funds. This client memo discusses what is known about the investigation, the scope and potential application of the FCPA in this context, and steps that firms may need to consider in connection with their interactions with sovereign wealth funds.