Oil dipped below the $50-per-barrel threshold. What does this mean for energy companies trying to avoid prosecution for corruption while doing business with countries and companies overseas? The context is that the energy industry has had more enforcement actions under the Foreign Corrupt Practices Act than any other single industry.

At this point, energy companies face two increasing compliance risks. The first is that companies will attempt to reduce their costs by cutting their compliance personnel. Cost-cutting also means that companies that will not invest the monies needed to beef up their oversight through technological solutions. Secondly, what will be the pressure on the business folks of such companies to “get the deal done” amid this drop in oil prices? Further, if there is a 10 percent to 30 percent overall employee reduction, what additional pressures will be on remaining employees to make their numbers or face the same consequences as their former colleagues?

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