Can doing business with a specific customer – in and of itself – be a Foreign Corrupt Practices Act “red flag”?

That seems a bit harsh, particularly when the company has approximately 125,000 employees.

Then again, as set forth in this post, it is hard to ignore that a dozen corporate FCPA enforcement actions have involved – in whole or in part – bribery schemes involving employees of Mexico’s Petróleos Mexicanos (PEMEX) and it various subsidiaries and affiliates.

Set forth below are the numerous corporate FCPA enforcement actions that have involved – in whole or in part – bribery schemes involving PEMEX.

These are in addition to numerous individual FCPA enforcement actions as well (including this recent individual enforcement action).