“In the most highly publicized and costly prosecution to date, Siemens AG paid $800 million in civil and criminal fines to the DOJ and SEC for corrupt payments occurring around the world. Siemens made 4,238 separate bribes totaling approximately $1.4 billion to numerous foreign officials to gain contract work. Siemens’ bribes included payments on transactions to design and build metro transit lines in Venezuela, metro trains and signaling devices in China, power plants in Israel, high voltage transmission lines in China, traffic control systems in Russia, refineries in Mexico, and national identity cards in Argentina (to name a few). The company even had “cash desks” containing thousands of U.S. dollars which could be conveniently stuffed in a suitcase and carried to a corrupt foreign official.[2] For Siemens, “bribery was nothing less than standard operating procedure.”