The article sums up how you can prevent huge fines, just by having proper controls in place. There are always cracks in the wall, but you have the opportunity to say you did your best!
The Department Of Justice sums up their paean to Morgan Stanley—to Raja, really—with the declination:
After considering all the available facts and circumstances, including that Morgan Stanley constructed and maintained a system of internal controls, which provided reasonable assurances that its employees were not bribing government officials, the Department of Justice declined to bring any enforcement action against Morgan Stanley related to Peterson’s conduct. The company voluntarily disclosed this matter and has cooperated throughout the department’s investigation.
Detailed article link: here