The frequency and magnitude of Foreign Corrupt Practices Act of 1977 (FCPA) (15 U.S.C. § 78dd-1, et seq.) investigations and claims continue to grow. Last month, the U.S. Securities and Exchange Commission announced that Halliburton Co. had agreed to pay $29.2 million in fines and penalties to settle allegations that its operations in Angola and Iraq violated the FCPA’s books and records and internal accounting controls provisions. In its press release, Halliburton vowed that it had “continuously enhanced its global ethics and compliance program” since first receiving an anonymous tip in December 2010, but the recent settlement serves as a reminder that even the most robust compliance program cannot guarantee that FCPA violations will not occur.