Siemens is upbeat about its chances of getting its insurers to pay a big chunk of the $1.3 billion it paid to settle corruption probes in the United States and Germany. And that's a worry because it leaves you wondering whether the company has learned any lessons from the debacle.

Lawyers say there are several lessons to be drawn from the Siemens saga. The most obvious is that the provisions of the Foreign Corrupt Practices Act do not just apply to US companies. Anyone can be caught in the net.

But as the lawyers say, the interesting part is that Siemens use of third parties was no shield. Siemens engaged third parties with no expertise in the specific industry and parties that simultaneously worked for the government entity the company was targeting for business. There was also the issue of success fees. The lawyers write: "These FCPA red flags went undetected because, in part, Siemens rejected suggestions to create a company-wide list of third parties and to form a centralized committee to review third-party relationships."

Only time will tell whether Siemens has learned anything. But the case is definitely a wake-up call for companies doing business in overseas markets.