The list of companies facing charges from the Securities and Exchange Commission and the Department of Justice over violations of the Foreign Corrupt Practices Act continues to grow. Many of the more recent additions to that list, however, thought they had rock solid anti-bribery compliance programs in place.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...