The second half of 2008 and early part of 2009 proved to be another watershed period for Foreign Corrupt Practices Act ("FCPA") and anti-corruption enforcement.  Although the pace of announced FCPA settlements and prosecutions slowed somewhat from the breakneck pace of early 2008, the sheer size of certain settlements and their attendant implications may prove to alter the way in which companies world-wide address anti-corruption issues.  Notably, the long-awaited December 2008 settlement between Siemens AG and U.S. and German regulators resulted in over $1.34 billion in combined fines (approximately $1.6 billion when including a previous settlement with German regulators), dwarfing the previous largest combined penalty of $44 million imposed on Baker Hughes in April 2007.  The settlements with Kellogg Brown & Root, Inc. and Halliburton Company (formerly operating together under Halliburton), announced in February 2009 and totaling a combined $579 million in criminal fines and disgorgement, confirms that the Siemens settlement was not an anomaly.

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