The Corruption of Foreign Public Officials Act (CFPOA) was intended to prevent and enforce Canadian companies in foreign lands enabling corruption. To give them a by while they go to court is watering down the seriousness of the charges and the responsibility of the company and senior management to ensure that it does not happen. What process (Approvals) broke down at SNC to enable $ millions to be transferred. After working in the ME and NA, I am surprised that it has taken this long for charges, however it is a Quebec company so they have probably paid off Canadian's investigating. If they were charged under the US  Foreign Corrupt Practices Act or the UK Bribery Act would they get a by?