In an interview published in The New York Times in February 1976, former Lockheed president A. Carl Kotchian defended the payment of bribes by the company as follows:

Some call it gratuities. Some call them questionable payments. Some call it extortion. Some call it grease. Some call it bribery. I look at these payments as necessary to sell a product. I never felt I was doing anything wrong.

More than 30 years later, Reinhard Siekaczek, an accountant employed by Siemens who oversaw an annual budget for questionable payments in excess of $50 million, stated:

I never thought I would go to jail for my company. . . . We thought we had to do it. Otherwise, we’d ruin the company. . . . People will only say about Siemens that they were unlucky and that they broke the Eleventh Commandment. The Eleventh Commandment is “Don’t get caught.”

Given these attitudes, is the Foreign Corrupt Practices Act likely to result in a change in corporate culture at multinational businesses? Is the FCPA a success or a failure to the extent that its prohibitions are not taken seriously, as demonstrated by the above statements?