All of this should not be discouraging to companies worried about complying with anti-bribery laws.
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The second investigation, a joint probe with the Securities and Exchange Commission, concerns possible violations of anti-bribery laws.
The SEC and the U.S. Justice Department have been more aggressive in recent years in enforcing anti-bribery laws.
The affair could scupper the campaign to defang the FCPA. American firms have long grumbled that they are at a competitive disadvantage because other countries' anti-bribery laws are laxer.
The last decade has seen a consistent trend toward greater enforcement of anti-bribery laws against companies and individuals, both by the United States and, with a less steep trajectory, other countries.
Illicit payments continued for years after Germany outlawed the bribery of foreign officials in 1999 and after Siemens listed its shares on the New York Stock Exchange in 2001, which made it subject to America's tough anti-bribery laws.
In each case, prosecutors alleged violations of anti-bribery and bookkeeping laws spanning several decades, operating groups and regions.
But also because laws on bribery (which is harder to spot than theft) have grown tougher.
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While there was "welcome" evidence of progress in some areas, Mark Pieth - chairman of the OECD's working group on bribery - said current laws were not adequate.
The OECD said it was "seriously concerned about the UK's continued failure to address deficiencies in its laws on bribery of foreign public officials and on corporate liability for foreign bribery".
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