Allegations of a Foreign Corrupt Practices Act violation can easily cost a company hundreds of millions of dollars. And that’s before the U.S. Department of Justice or the Securities and Exchange Commission levies one dollar in fines or penalties.
Internal investigations can quickly spiral into multi-million dollar affairs. Walmart, for example, spent nearly half a billion dollars over two years on its investigation into possible FCPA violations, according to a January Form 10-K filing. When Avon, announced results for its first quarter, it said it accrued a total of $135 million related to its FCPA investigation; its settlement with the SEC and Justice Department would run another $135 million.
