The SEC’s recent announcement that it had settled charges of alleged FCPA violations against former Sociedad Química y Minera de Chile (SQM) CEO Patricio Contesse González with a cease-and-desist order and a $125,000 penalty may lead some to wonder whether the punishment fits the alleged crime. After all, just last year, the company itself agreed to pay the U.S. government some $30 million in criminal and civil penalties largely for its mishandling of a discretionary fund provided for the use of Contesse. We compare this outcome to that in the PetroTiger case and tease out compliance lessons on how to prevent corruption at the very top of an organization. See “$30M SQM Settlement Demonstrates the Hazards of Discretionary Accounts for CEOs and Charitable Donations to the Politically Connected” (Feb. 15, 2017).