As nations intensify their enforcement of anticorruption laws, multinational corporations face enormous civil and criminal financial risk. The most painful reminder of this came in 2008, when Siemens agreed to pay fines totaling $1.6 billion to settle bribery charges brought by U.S. and German authorities. Huge though that was, it was by no means an anomaly. As recently as February, telecomm provider VimpelCom was required to pay $795 million to resolve bribery charges brought by U.S. and Dutch regulators.
Even before any finding of wrongdoing, the cost of just defending against anticorruption charges can be huge. From 2012 to 2015, Wal-Mart Stores spent at least $650 million simply responding to a Foreign Corrupt Practices Act investigation of its Mexico business by the U.S. Department of Justice, even though the investigation reportedly turned up no significant violations.
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