Despite calls for utilizing white-collar and corporate crime frameworks to study corruption, the role of corporations in supplying bribes to foreign government officials is not well understood. In the current study, we draw upon a recent framework designed to examine the transnational corporate bribery process from an opportunity theory perspective. We apply the framework to a sample of individuals and organizations with enforcement actions levied against them by the United States Department of Justice’s Fraud Section for violations of the Foreign Corrupt Practices Act of 1977 between 2011 and 2016. Using an exploratory mixed methods approach, we assess the prevalence and qualitative nature of multiple components of the framework. Our goal is to develop a systematic way to apply it to different sets of bribery data and to move toward a fuller theoretical account of transnational corporate bribery. Our findings demonstrate the significance of the corporate role in foreign bribery, the utility of the bribery process framework, and some areas of refinement and future theoretical development.