The FCPA is enforced by the US Department of Justice DOJ and the US Securities and Exchange Commission (SEC). Even if there is no criminal prosecution, the FCPA empowers the SEC to file a civil action for disgorgement and penalties if your company does not have adequate internal controls or improperly recorded expenses in your books and records. Other countries have similar requirements. For example the UK Bribery Act requires that companies are subject to strict liability for failure to prevent bribery unless they have adequate procedures in place.