First, it was Morgan Stanley in 2012. Now, for only the second time in the history of the Foreign Corrupt Practices Act (at least, that’s been publicly reported), the Department of Justice this week exonerated a company from FCPA prosecution, despite guilty pleas by three of its top executives.

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,...