Sometimes it's difficult to see what advantage has been derived by companies that settle with U.S. authorities after self-reporting alleged violations of the Foreign Corrupt Practices Act.  And the long-winded agreement is just the beginning of a long and costly process.  As the Wall Street Journal reports, a company that confesses to its violations

[C-I Note: It's unlikely a company will confess if they're dealing with an alleged, possible, likely violation.  No, an internal investigation will be have been completed, or substantially completed by the time a company walks into the offices of a U.S. authority.]

The companies typically will spend millions to revamp compliance policies and procedures, and anti-corruption policies, and to bulk up legal reviews.  The Justice Department requires some companies to pay for a compliance monitor - usually an outside lawyer - to keep tabs on the company's efforts at bettering itself and reports. So far in 2011, criminal fines arising from FCPA settlements have exceeded $270 million.  That's up from $11 million in 2004. Ongoing Obligations - Re-Enactment of Guess Who's Coming to Dinner. Like an SEC field examination, where the examiners seems to hang around for weeks or months, companies entering into FCPA agreements are in for a long-term relationship with U.S. regulators.  And those that fail to live up to their negotiated obligations, do so at their own peril. The Justice Department can, for example, void the settlement and seek an indictment for breaches of deferred prosecution agreements, the  preferred means for punishing a company without addling it with criminal charges. Companies that successfully complete fulfill their obligations get released.  But that usually runs for a minimum period of some 3 years.  The SEC can do the same, with civil charges. Collateral Consequences. Okay, so you're representing a company that's "dotted the i's and crossed the t's".  According to WilmerHale partner Roger Witten, there can be collateral consequences.  A government contractor, for instance, could face suspension or debarment.

e.g. - engineering giant Siemens AG was suspended from bidding on UN and World Bank contracts following its 2008 bribery settlement.

Foreign Investigations. Just so everyone gets an opportunity for "a slice of the pie," foreign governments follow up by requiring companies to provide documents, testimony and other evidence that came to light in the U.S. and internal investigations.  That, in turn, provides foreign officials, to seek their fare share of fines and/or sanctions.   [WSJournal, 10/20/11]