For Peeler, among the most shocking findings of the study was that, since 2005, 13 percent of individuals criminally charged with an FCPA violation only had a general suspicion that bribes were being paid. In those cases, the individuals did not have direct confirmation of bribes or involvement in them. Peeler described that finding as “mind-blowing.”“That means the hair on the back of their neck stood up. Something made them think it could be happening. They didn’t take any action to facilitate it or to do it themselves. And no one ever told them it was actually going on,” Peeler said. But a little more than one out of 10 people in that situation were charged with a criminal violation of the FCPA, where jail is on the line. That’s a big thing.”He continued: “If you’re aware that bribes are happening and you take a step the government believes furthered that to go on, the chances that you get charged criminally, I don’t think, is that surprising. I think what is surprising is how low the bar is before you can face that extreme charge,” he added. “I think that’s a big deal.”

Fifty-three percent of charged individuals were C-suite level.

Of the individuals charged—either criminally or civilly—with an FCPA violation, more than half held high-level positions such as president, vice president or director.According to the study, officials in senior roles were more likely to be charged during the past seven years than they were between 2005 and 2011—the range of Arent Fox’s initial FCPA study.“The idea that they’re not going heavy against the C-suite is nuts. They are. And it’s got a deterrent effect. But that’s not to say they won’t go for sales reps and other people down the chain,” Peeler said. “It’s just extraordinary to think that more than half the people charged are folks who are running the show. And so, therefore, when you’re deciding to allocate focus and attention on compliance, you’re not only making the right decision for your company. You’re making the right decision for your people and for yourself, too.”

Thirty percent of the cases derived from Latin America.