As many practitioners in the compliance community will attest, a significant number of FCPA violations can come across their desk. How can a company ensure that possible FCPA violations are acted on consistently and equitably? In a guest article, Matt Herrington and Stephanie Wang of Steptoe & Johnson propose an analytical tool that allows companies to distill allegations regarding FCPA violations into certain quantifiable factors, allowing compliance officers to create a methodological approach to what investigative response should be taken in any given situation. Such an analysis makes it easier to identify similar allegations and act consistently and, in the event that the government ends up being involved, this severity analysis can help justify the actions taken by the company. Herrington and Wang demonstrate the use of their proposed tool with five hypotheticals and illustrative graphs. See also “Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Program” Part One (Feb. 24, 2016); Part Two (Mar. 9, 2016).