There have been many theories as to why this increase occurred. One is that companies were forced to review and report failures in books and records testing required under Sarbanes Oxley. Another, perhaps more cynically, is that the government discovered a cash cow in the form of fines, penalties and profit disgorgement from FCPA criminal and civil enforcement actions. However, Cassin presented another theory, being that the change all came about after 9/11.
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