Siemens FCPA Cases Teach FCPA Dos & Don'ts

A story in today's Compliance Week discusses the lessons learned from the FCPA enforcement cases brought against Siemens AG and several of its foreign subsidiaries by the Justice Department and Securities and Exchange Commission.

The article notes:

Siemens’ new management is practically doing a road show of self-confession, speaking at conferences and holding Webcasts to discuss how the company managed the investigations and pieced its compliance function back together again. Experts say large companies everywhere can take away lessons of what to do, and what not to do.

In addition, the article contains some staggering statistics on the scope and cost of the investigation. Joel Kirsch, head of Siemens’ U.S. compliance activities, said:

Siemens footed the bill for more than 200 outside lawyers and support staff from the law firm Debevoise & Plimpton, plus another 1,300 forensic investigators from Deloitte; the two firms racked up a total of 1,531,000 man-hours on the project. Siemens itself had 16 employees working on the probe full-time.

In all, investigators conducted more than 1,150 interviews, reviewed more than 14 million documents, and analyzed 38 million separate financial transactions, Kirsch said. Total cost of the investigation: $850 million.

The story also contains other useful information on how Siemens has upgraded its compliance functions and how other companies can learn from this case.