Settlements can provide an important channel to hold companies to account for wrongdoings and resolve foreign bribery and other cases without resorting to a full trial (civil or criminal), or contested administrative proceeding.

Yet, their deterrent effect can be questionable if they are not transparent, and do not provide effective, proportionate and dissuasive sanctions and if there is no judicial process. Finally, there should be reparations for the victims of the offence.