Many compliance and ethics programs originated as a way to mitigate foreign bribery risk. However, as compliance has demonstrated its effectiveness in preventing and detecting all sorts of crimes, it has become a deciding factor in settlements beyond the FCPA. In September 2026, Southern Glazer’s Wine and Spirits, LLC, was able to settle domestic commercial bribery charges with a non-prosecution agreement in part because of its compliance program. The Anti-Corruption Report spoke with both defense counsel and in-house experts to understand what the settlement indicates about compliance expectations for companies operating within the United States. See “Commercial Bribery: The FCPA’s Forgotten Counterpart” (Jul. 8, 2020).