FCPA investigations are a dime a dozen these days, but a new Deloitte poll shows that most companies don’t seem to be reacting. The study found that only 32 percent of respondents to the Deloitte online poll acknowledged that they were stepping up their internal FCPA controls to prevent violations.

According to the statement from Deloitte:

“FCPA prosecutions have increased dramatically in recent years, and all indications are that this trend will continue,” said Ed Rial, leader of Deloitte’s Foreign Corrupt Practices Act Consulting practice. “The Department of Justice and Securities and Exchange Commission have repeatedly identified the FCPA as an enforcement priority and have added staff dedicated to the investigation of suspected violations. As more U.S. companies seek to expand into developing foreign markets — many of which have spotty reputations for corruption — the need for effective anti-corruption programs and controls to prevent and detect potential violations is critical.”

The three most-likely sources of potential FCPA violations, as identified by respondents, were “agent/consulting relationships (30.3 percent), foreign subsidiaries of U.S. companies (28.4 percent) and joint venture or strategic alliance partnerships (21.8 percent).”

While “consulting relationships” do get companies in a heap of trouble, it’s surprising that foreign subsidiaries came in second, as a number of recent cases came from this area.