Either investigative techniques used to uncover FCPA violations are improving, more companies are doing it or it’s just getting more attention from the DOJ. But whatever the reason, FCPA cases are a dime a dozen these days. The most recent alleged violator: Shell Oil. The company is being looked into by the Department of Justice and has also announced its own internal investigation. The company says it is cooperating fully and acknowledged that it may have to pay “fines and additional costs,” according to its most recent annual report.

Generally violations come from smaller company subsidiaries and, of course, this instance is no different. Shell’s “basel-based logistics firm” Panalpina is the culprit this time. Panalpina has allegedly bribed officials in Nigeria, Kazakhstan and Saudi Arabia, however since the investigation began the firm has ended operations in Nigeria.

The take-home message? Yes, your subsidiaries can get you in a heap of trouble. Don’t limit your compliance and code of conduct training to your primary business. It’s just as important to make sure that all the small little offices working for you in the most obscure parts of the world are following protocol as well. If not, your company name could very quickly be next to the words “FCPA” and “Violations” in next week’s headlines (and judging by the rate FCPA violations are being investigated, there will likely be another one next week, if not sooner).