More than five years after the resolution of its FCPA case, Siemens AG still holds the title for the highest fine paid in an FCPA matter. The company continues to set FCPA records – on February 4, 2014, two of its former executives were ordered to pay the largest individual civil penalties in the history of FCPA enforcement. Adding to the historic nature of the event, Stephan Signer and Ulrich Bock were sentenced after failing to enter an appearance in the case pending against them since 2011 and choosing not to file any responsive pleadings. See “Lessons Learned on Crafting FCPA Compliance Programs from the Largest FCPA Case in History
” (July 11, 2012).