While the Foreign Corrupt Practices Act was originally intended to prohibit the payment of bribes to foreign officials by U.S. businesses, many of the top companies who have paid the largest settlements are based outside the United States. As more companies operate across the globe in a near "borderless" fashion, it has become increasing difficult to determine if a company is foreign or domestic.
"The world is flat,'' said Matt Reinhard. "You could be based on Mars and Justice will come after you. There was a period before Siemens when the culture of compliance was not as prevalent in foreign-based companies as those in the U.S. But there is a cultural shift, and the U.S. is on the crest of this wave."