For a publicly traded corporation, an FCPA investigation, or even settlement, may be only the beginning of the company’s anti-corruption woes. In recent years, news reports of corruption have launched numerous shareholder securities cases and derivative litigations. The risks associated with collateral FCPA actions are well known, but recent developments in several key cases further illustrate how collateral actions can take on a life of their own, creating years of litigation and costing companies millions of dollars beyond any penalties paid to the government. See “How to Anticipate and Manage Collateral Litigation after an FCPA Investigation Becomes Public,” The FCPA Report, Vol. 2, No. 17 (Aug. 21, 2013).