The Siemens case is undoubtedly the biggest case in FCPA enforcement history: the “pattern of bribery” involved was “unprecedented in scale and geographic reach.” The $1.6 billion combined settlement with U.S. and German authorities remains the record-breaking anti-corruption penalty of all time. But what was missing from the Siemens case was the “cornerstone” of the Department of Justice’s “enforcement strategy”—not a single individual had been held accountable for the conduct at Siemens. That is, until yesterday.

Almost exactly three years to the day since Siemens AG and three of its subsidiaries, including Siemens Argentina, settled the massive FCPA case, the DOJ announced yesterday charges against eight Siemens former executives and agents. The indictment alleges that the eight individuals were involved in a conspiracy to funnel $100 million to Argentine officials to land a $1 billion contract to make national identification cards. The defendants were charged with conspiracy to violate the FCPA, conspiracy to commit wire fraud, substantive wire fraud, and conspiracy to commit money laundering. In a parallel action, the Securities and Exchange Commission charged seven individuals.