An activist shows fake banknotes during a demonstration outside the European Commission (EC) headquarters ahead of statements by the EC on the effectiveness of existing measures against tax evasion and money-laundering in light of the recent Panama Paper revelations, in Brussels, Belgium, April 12, 2016.
Yves Herman / Reuters

For most of the past four decades, a recurring nightmare has plagued corporate counsels, risk managers, and the CEOs of the world’s largest multinational corporations. Ever since the U.S. Foreign Corrupt Practices Act (FCPA) was enacted in 1977, they’ve believed that somehow, somewhere, in spite of millions spent honing compliance systems and a robust anti-corruption ethos, some failure of process or principle in one of their far-flung global operations would bring the U.S. Justice Department’s criminal division knocking at their door. 

“It was not terribly long ago,” the chief counsel of one of the world’s

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