The risk of an FCPA case saddling a violating company with large restitution payments is one of the lessons that can be drawn from the news that a federal district court in late February ordered Glencore International to pay millions of dollars in restitution. The multinational commodity trading and mining company pleaded guilty in 2022 to conspiring to violate the FCPA. The court ordered that Glencore pay $29.6 million in restitution. The case highlights how important it is for companies to anticipate that risk when involved in FCPA investigations. See “Glencore Pleads Guilty and Agrees to Pay $1.1 Billion to Multiple Authorities, But Can It Change?” (Jun. 22, 2022).