Kirby Behre and Lauren Briggerman commented on the increasingly limited reach of U.S. Department of Justice (DOJ) enforcement of corruption charges on companies and individuals globally. "These foreign executives are ignoring the DOJ's efforts to hold them accountable," Behre said. "As these investigations become more and more global, this is an issue that the DOJ is going to have to grapple with: how are they going to indict foreign executives who do not willingly submit to U.S. jurisdiction?"

Obtaining extradition has not been a given in many cases. For example, in cases for which the conduct that the U.S. is seeking extradition is also prosecutable in the host country, the host government may want to take the matter into its own hands, Behre said. During the DOJ investigation of the auto parts industry, of the 52 individuals charged, 22 are Japanese nationals who have refused to submit voluntarily to U.S. jurisdiction, according to both lawyers. In such cases, the Justice Department may need to drum up international support around a crime that has affected the public generally, or find a scenario that is palatable for the foreign country, Briggerman said. "The idea that Japan would now extradite a busload of people is slim to none," Behre said. "The DOJ is not ignoring reality, but they're certainly not publicizing it."