The DOJ has announced a grand jury indictment of U.S. citizen Jason Edward Steph on charges that he conspired to make corrupt payments to Nigerian officials in violation of the Foreign Corrupt Practices Act (FCPA).

Steph, age 37, is a former executive of a subsidiary of Houston-based Willbros Group Inc. According to the indictment, Steph conspired to make more than $6 million in bribes.

There are four counts in the indictment that accuse Steph of conspiring to bribe the officials while serving as general manager of Wilbros (a publicly-traded company) between 1998 and 2005.

Commentary: Want a throw around a figure that can help scare your employees into compliance with FCPA? Steph faces up to five years in prison for the charge of conspiring to violate the FCPA. He also faces money laundering charges since the money for the bribes was transferred internationally. Furthermore, he faces fines of either $500,000 or 2x times the amount of the “gain.”

Take out the calculator it adds to (tap….tap….tap…) UP TO 60 YEARS IN PRISON AND POTENTIALLY MILLIONS OF DOLLARS IN FINES. Of course, he is not going to get that if convicted (our guess is that he gets less than 3 years) – but all the same, the uncertainty of how significant the penalty could be is enough to make any 37-year-old’s hair turn prematurely gray.