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In 2008, when Siemens AG and three subsidiaries pleaded guilty to Foreign Corrupt Practices Act (FCPA) violations and agreed to pay $450 million in combined criminal fines, the resolution put the world on notice.[1] Violating the FCPA – including through corrupt payments, falsified records, and weak internal controls – would result in significant penalties. Paying bribes to foreign officials now carried enterprise risk. While that seems obvious today – after a number of subsequent multi-billion-dollar FCPA settlements – it wasn’t always the case. Through the work of a small but dedicated group of prosecutors at the U.S. Department of Justice, the FCPA developed from an esoteric and underappreciated area of the law into one of the top risk and compliance areas for large companies. Export enforcement is now travelling a similar path.