A car and truck manufacturer just found out that two of its overseas business units have been engaging in bribery over a 10-year period of time. The company paid $56 million in bribes to more than 20 countries to gain government contracts for their vehicles.3 The company is now paying millions in criminal and civil charges because of its violation of the Foreign Corrupt Practices Act (FCPA), and it admits to earning more than $50 million in profits based on its corrupt transactions. The car company recorded the bribe payments as commissions, special discounts, or necessary payments.

Should the manufacturer discontinue its operations with the countries that were unlawfully bribed to buy its cars? Are financial fines sufficient to repair the problem? How can companies be sure the commissions they earn are true commissions and not a bribe?