In the first few months of 2014, the SEC has already brought as many enforcement actions under the Foreign and Corrupt Practices Act (FCPA) as through all of 2013.

These enforcements span a range of business sectors, but there are a number of reasons why the global oil and gas sector is specifically exposed to bribery risk. High-level management will need a clear strategy for dealing with it, before the investigators knock at their door.

In 1921, when President Warren G. Harding's secretary of the interior took kickbacks to lease naval oil reserves to a group of oilmen, the Teapot Dome scandal became the bribery case of a generation. Since then, the oil and gas industry has kept up its reputation as an environment where bribery has too often been the norm.

From 2008-12, oil and gas made up nearly one-fifth of prosecutions under the United Kingdom's Bribery act. It is also a world where lavish gifts and entertainment have been common, an area where a new generation of anti-bribery legislation is cracking down if intent to influence business decisions is suspected.

Since the 1920s, the end of the era of easy oil meant that oil companies have ventured further and further from U.S. shores. With that process (in industry speak), the "commercial and operational risk profile" has shifted since the days when plentiful oil could be found in the U.S. or off the shores of developed European countries in the North Sea.

There are several reasons why the oil and gas industry of today is exposed to particular bribery risk.

First, the jurisdictions where these resources are increasingly found coincide with some of the countries with the highest corruption rates in the world. In Transparency International's 2013 Corruption Perceptions Index, the bottom 10 scoring countries (of 173 in total) account for 12.2 percent of the world's proven oil reserves and 12.6 percent of gas reserves.

They also include important emerging frontier oil and gas producers like Afghanistan and Somalia. "Resource curse" literature has long made the link between oil wealth and unusually high levels of corruption, as plentiful resource rents lead to widespread "rent seeking" behavior, often resulting in a stubborn culture of bribery.

Signing bonuses, of as much as $1 billion in oil states like Libya, present something of a gray area. They are not made explicitly illegal by the FCPA, but "unusual bonuses, one-time success fees or extraordinary payments" do constitute a red flag.

Another feature of the oil and gas industry is the necessity for partnerships, calling for vast networks of consultants, joint venture partners and an array of service companies. This can bring about significant partner risk, as the U.K.'s Tullow oil recently found out when it was forced to default on its contractual drilling obligations in Guinea as U.S.-based partner Hyperdynamics Corporation was probed by the SEC and the DOJ.

The FCPA clarifies that a company only needs sufficient knowledge to suspect violations of the Act to be liable, and violations of the Act by third parties have become a common occurrence.

Heavy and rising state involvement in the industry can be another weak spot. The FCPA prohibits paying bribes to foreign officials for business, defined by law as "any officer or employee of a foreign government or any department, agency or instrumentality thereof."

Thus, this covers the ranks of the various ministries, government offices and bureacratic agencies that a foreign executive might be dragged through in order to get a project passed, as well employees of the state-owned oil companies that now control 90 percent of the world's petroleum resources.

Making a telephone call, sending an e-mail, writing a text message or sending a fax from, to or through the United States involves interstate commerce, according to to the FCPA Guide, and so can be used as evidence for a violation. But given the global nature of the operations of many oil companies, compliance cannot stop at U.S. legislation.

The U.K. Bribery Act — dubbed by some lawyers as "the FCPA on steroids" — goes beyond its American counterpart, prohibiting the bribery of private actors and local public officials, rather than only foreign officials. But domestic legislation in oil-producing countries needs to be fully understood and acted upon.

Take the example of Mexico's newly-reformed energy sector, where the 2012 Mexican Federal Anti-Corruption Law for Public Contracts, like the U.K. Bribery Act, makes no exceptions for "facilitation payments," among other harsh provisions. Whether the Mexican government will have the courage to enforce this remains to be seen, but firms should be aware that an ambitious Mexican administration may be keen to make an example of someone to show the international community they mean business.

The process may be burdensome, but ultimately what the crackdown on bribery in the U.S. and abroad is doing is what governance policies must do. It makes a clear business case for good governance whereby international companies begin to see anti-corruption initiatives less as a tedious chapter in a company brochure and more as insurance against multimillion dollar fines once investigations come to a conclusion.

An industry report notes that such changes not only have a role in protecting private and public finances, but also play a key part in establishing the much-hyped "social license to operate" for a firm in a jurisdiction. In short, a proactive approach to compliance in line with more aggressive legislation is in everyone's interests.