A reminder for compliance professionals who think they've got Foreign Corrupt Practices Act compliance in the bag: Don't forget to do a regular gut check.

It's often said, but it bears repeating: That program you have in place only works if it's properly implemented and monitored. “Companies often put a program in place and think they've done their job, but day-to-day nobody's checking that it's working and being used,” says Stuart Altman, a partner in the law firm Hogan Lovells.

Given the current anti-corruption enforcement climate, being able to demonstrate that your program is actually being used is even more important than ever, says Altman. That means having someone—whether it's compliance, internal audit, or an outside consultant or vendor conduct periodic checks to make sure the program is operating as intended. It also means keeping a record of any due diligence to be able to show that the company took the proper preventative measures to avoid a problem if one should arise.

Altman also shared his views on FCPA enforcement trends compliance executives should keep in mind. Most notably, big investigations, big cases, and big penalties are here to stay. The latest enforcement statistics are proof that the Department of Justice is delivering on its promise of increasingly aggressive FCPA enforcement.

“2010 marked a real change in both volume of cases and the way cases are investigated,” says Altman. While past years saw one or two marquee enforcement actions accompanied by a flurry of smaller actions, last year marked a succession of high-dollar value settlements and penalties across a range of cases. Indeed, eight of the all-time 10 largest FCPA penalties in history were handed down in 2010. Altman expects that to be the rule, rather than the exception going forward. “The days when a company could get off with a relatively small fine and a promise not to do it again are gone,” he says.

Enforcers are proactively pursuing FCPA investigations, as evidenced by the 2010 FCPA sting operation that resulted in the arrest of 22 people. And where they do find a case, they're quick to expand their investigation to other companies.

Companies should also be prepared to conduct more investigations into alleged FCPA violations thanks to the new Securities and Exchange Commission whistleblower bounty program being established under the Dodd-Frank Act. “Companies have to be prepared to do thorough investigations to prove a spurious complaint,” says Altman.

Non-U.S. companies in particular ought to shore up their compliance efforts. While those companies are increasingly the target of FCPA enforcement actions, “A lot of companies with minimal ties to the U.S. operate under the belief that they're free from concerns about FCPA compliance and don't have strong compliance programs in place,” says Altman. Nearly all of the largest Justice Department enforcement actions in 2010 were against non-U.S. companies.

Thanks to increased cooperation, resources, and coordination, companies should expect more follow-up on cases—both within the U.S. and from foreign enforcement agencies. Where the Justice Department brings a case, the SEC often follows and vice versa. As U.S. enforcers increase their coordination and cooperation with their foreign counterparts, such as the United Kingdom's Serious Fraud Office, companies will face global anti-corruption enforcement.