The circle is now complete. Beginning with the Yates Memo last September to the metrics laid out by Assistant Attorney General Leslie Caldwell in November through to the comments by the new Justice Department Compliance Counsel Hui Chen in December, all culminating in the announcement of the Justice Department Pilot Program in March—enforcement of the Foreign Corrupt Practices Act (FCPA) has taken a dramatic turn. And, the results from three recent enforcement actions demonstrate that if companies follow the requisites of the Pilot Program, they will sustain real and tangible benefits for their FCPA violations.
