Coughing up Executives or Rolling the Dice: Individual Accountability for Corporate Corruption

Abstract

Anti-bribery enforcement continues to intensify on a global scale. More than ever before, multinational corporations currently face high financial and reputational risks relating to bribery and other corrupt practices. These increasing risks result predominantly from an escalating enforcement of the U.S. Foreign Corrupt Practices Act (FCPA). This escalation is clearly demonstrated by an increase in the ticket price of FCPA actions in recent years: in 2014, for instance, companies paid on average more than $150 million to resolve FCPA cases. This value is about seven-and-a-half times higher than the average total value of monetary resolutions of corporate FCPA cases in 2012 and almost double the same value in 2013.