This is an excel­lent exam­ple of how the com­bi­na­tion of an anony­mous tip line and proac­tive man­age­ment min­i­mized the finan­cial impact of FCPA vio­la­tions. How­ever, one has to won­der whether this could have been uncov­ered dur­ing due dili­gence pro­ce­dures, even if these subs were merely part of a larger tar­get that was acquired. Iden­ti­fy­ing and test­ing accounts with inher­ent FCPA risk (freight and other high-volume accounts) and (pro­mo­tional prod­uct and other sales and mar­ket­ing accounts) might have caught this sooner.