There's something about bribery that just seems old school. It calls to mind shady operatives, exotic locales, suitcases stuffed with cash. It's the stuff of a Graham Greene novel, not a sophisticated global enterprise. Nobody really does that anymore, right?
Well, some things never go out of style. Take, for example, the ongoing corruption saga of the massive German conglomerate Siemens AG: more than $2 billion in international bribes revealed so far; implicated parties as high up the organizational chart as the CFO and the managing board.
About two-thirds of investigation activity is a direct result of the maturation of the global enforcement community, according to Newcomb. The remaining third stems from self-reported violations.
Internal compliance efforts often turn up problems. Others emerge during M&A due diligence. Companies that self-report can expect a more pragmatic response from the DOJ than in years past.