Last month in remarks to the New York City Bar White Collar Crime Institute Deputy Attorney General Rod Rosenstein announced a new “anti-piling on” policy for global anti-corruption enforcement actions. This was the formal extension of the “one-pie” concept previously articulated in 2016 by Kara Brockmeyer, then-chief of the FCPA Unit at the SEC, and Daniel Kahn, (then and current) head of the Justice Department FCPA Unit.
