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.