Just when you think things cannot get any bigger, any stranger, or any weirder, the FCPA anti-corruption world continues to grow in all three of those manners. In 2012, the New York Times broke the story of alleged bribery by the world’s biggest retailer, Wal-Mart, in Mexico. In 2013, there was the first prosecution by the Chinese government of a western corporation, GlaxoSmithKline, for violation of domestic Chinese anti-bribery laws. In 2014, the Petrobras corruption scandal broke under the rubric of a car wash, which may well bring down President Dilma Rouseff of Brazil. In 2015, the leaders of the world’s largest sporting organization, the Fédération Internationale de Football Association (FIFA), found themselves in the crosshairs of Justice Department criminal prosecutions for systemic corruption. Later in 2015 the Volkswagen emission-testing scandal— which certainly will become the world’s largest, most costly, and all-encompassing environmental corruption scandal—broke.
So forgive me for thinking things could not get any bigger. Yet in the month of February 2016, there were more FCPA prosecutions in that 30-day period than in the entire 2015 calendar year. But it does not stop there. In late March, the Huffington Post broke a story involving Unaoil, which may well be one of the harbinger events in the global fight against corruption and in anti-corruption compliance.
