Lessons Learned on Crafting FCPA Compliance Programs from the Largest FCPA Case in History

With the recent criminal and civil charges brought against former Siemens executives, a new chapter in the Siemens case has begun.  Siemens paid a record-setting fine to the U.S. government of $800 million in 2008 and over $800 million to German authorities, and conducted an internal investigation with a $1 billion price tag.  What did we learn – and what are we still learning – from this groundbreaking case?  In a guest article, William P. Olsen and Anne M. Eberhardt, Principal and Senior Manager, respectively, in Grant Thornton’s Forensic and Valuation Services practice, review the history of a company that revolutionized the world’s communications and electrical industries, follow its move to a business model that was almost entirely based on corruption, and analyze its landmark settlement with U.S. officials and the pending individual indictments, addressing the key compliance precedents the Siemens matter has set.

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