[mrandish]

> mandatory remediations for past transgressions.

Weirdly, this can actually cause companies that didn't do the bad thing (bribes, etc) to voluntarily, proactively adopt widespread, comprehensive, mandatory, highly-audited training to tell every single employee NOT to do that bad thing. That way, if some rogue employee(s) do that thing, having the audited paper trail proving how very hard the company tried to NOT do that thing, can be invaluable in defending the company. In the event of prosecution it can lower the penalties but even better, it helps in diverting potential prosecution into a settlement / consent decree - as well as negotiating lower penalties and settlement amounts.

This was actually the source of one onerous training requirement at BigCo, which I learned about over drinks with our Chief Legal Officer. Apparently, one company (not us) having an extreme punitive penalty slapped on them generates scary WSJ headlines every compliance training vendor uses on Slide #1 in their sales pitches.