The new anti-bribery prosecution regime involves serious charges and penalties for bribery in ...

Reasons supporting high fines at the start:
 Sends a strong message to leave no doubt of the risks of bribery
 Encourages ethical behavior on questionable actions before they become illegal
 Low fines may be considered a cost of doing business, and produce no change in behavior.
 Low fines could send a signal that the new anti-bribery regime is not considered high priority for investigators, so they may turn to more important areas.
 New laws and/or more rigorous enforcement of existing laws do not happen without some public debate or notification.
 More revenue for the government.
Reasons against high fines at the start:
 Unfair to levy high fines on unsuspecting companies
 Companies need time to change policies and practices
 Companies will lose business to competitors who bribe if the cost of bribery gets too high.
Conclusion  High fines are probably reasonable