Securing government contracts through deliberately disguised bribes recently landed Louis Berger International (LBI) in hot water with the DOJ. The New Jersey-based construction management company agreed to pay $17.1 million to settle charges that it violated the FCPA. Unlike other companies that have been rewarded for cooperation or self-disclosure with a below-sentencing guidelines fine, the LBI fine was within the statutorily suggested range. The company was also required, under the terms of the DPA, to engage a corporate monitor for a period of three years, a costly undertaking that the government has been requiring less frequently. This article explains the bribery scheme and what companies can learn from the settlement. See “Top FCPA Enforcers Tout Voluntary Disclosure and Warn About International Cooperation; The Defense Bar Responds” (Dec.3, 2014).