General Cable Corporation (GCC) has resolved FCPA charges with the SEC and DOJ based on a bribery scheme that spanned more than 10 years and half a dozen subsidiaries on two continents, and resulted in $51 million in profits. GCC, which self-reported, cooperated and remediated, will pay combined fines of more than $75 million pursuant to a DOJ non-prosecution agreement and an SEC order. The figure includes a significant discount off the Sentencing Guidelines, with no SEC fine separate from the disgorgement. A former senior vice president will pay $20,000 pursuant to a separate agreement with the SEC. The Anti-Corruption Report spoke with Ayoka Akinosi, an international specialist at Hughes Hubbard & Reed, and Kathleen Hamann, a partner at Pierce Atwood, to delve into the details of the case and the lessons the case holds for other companies, including identifying key performance indicators that may have mitigated the extent of the bribery scheme. See “Developing Key Performance Indicators and Tracking Metrics Using ISO 37001 (Part One of Two)” (Nov. 9, 2016); Part Two (Nov. 23, 2016).