Corporate buyers beware. That’s the advice of Billy Jacobson, co–general counsel at Weatherford International Ltd. When a U.S. company is planning to acquire an overseas business, it should do a thorough check for evidence of corruption, he says. If the deal goes through and prosecutors later find violations of the Foreign Corrupt Practices Act, the acquiror could be hit with criminal charges, as well as face multimillion-dollar penalties.

Jacobson should know—during a stint at the U.S. Department of Justice, he was the assistant chief for FCPA criminal enforcement. For the past year, he’s been building a model compliance program at Weatherford, where he serves as chief compliance officer in addition to co–GC. He was brought in after the Justice Department started an ongoing investigation of the giant oil and gas services company. Prosecutors are looking into allegations of overseas bribery and trade with sanctioned countries.