In this article, Leah Moushey discusses the McKinsey and SAP multi-million-dollar settlements resolving bribery investigations in South Africa, including the benefits of negotiated resolutions. "When it comes to enforcement, you need to take a step back and look at the underlying goals and what structures can be followed that can efficiently and effectively require parties involved in misconduct to take accountability, to try to make victims whole, and to defer future misconduct," Moushey said. Moushey added that FCPA corporate settlements have real consequences, as they compel corporations to take responsibility for criminal conduct and can result in reputational harm, shareholder lawsuits, and the risk of debarment.