This simulation involves an internal investigation by a French company, Santé, that has uncovered evidence of payments made as part of its operations in Africa that may trigger liability under the Foreign Corrupt Practices Act (FCPA). This course book introduces students to the FCPA, provides skills primers on interviewing a witness and counseling a client, and includes fact documents that form the backbone of the Santé problem. By participating in this highly dynamic and realistic course, students will not only learn about the FCPA, but they will also engage in essential lawyering skills, including fact development and analysis, interviewing, counseling, team building, project management, and problem-solving.