In an interesting article posted in Industrial Week.com, entitled “Rethinking FCPA Compliance Strategies in a New Era of Enforcement” attorney William Athanas took a different look at assessing the risks for manufacturing companies under the Foreign Corrupt Practices Act (FCPA). His thesis is that such companies assume that FCPA violations follow a “bell-curve distribution, where the majority of employees are responsible for the majority of violations.” However Athanas believes that the distribution pattern more closely follows a “hockey-stick distribution, where a select few…commit virtually all violations.”