On November 19, Leslie R. Caldwell, the Assistant Attorney General for the Criminal Division, spoke at the American Conference Institute’s 31st International Conference on the FCPA.  Ms. Caldwell began her remarks by noting that there have been significant changes in the Division’s FCPA work.  First, Ms. Caldwell emphasized that, due to the expertise and knowledge acquired over the years, the Department can investigate FCPA cases much more quickly and is better equipped to prosecute the individuals who are actually making the corrupt payments.  She specifically noted that more than 50 individuals have been convicted in FCPA and FCPA-related cases since 2009, and that half of those cases were brought in 2013 or 2014.  Second, she stated that the Department is increasingly working “shoulder-to-shoulder” with law enforcement and regulatory authorities in other countries, and that the increase in international collaboration is also resulting in anticorruption enforcement actions by other countries.  Third, Ms. Caldwell explained that the Department is increasingly stripping individuals of the proceeds of their conduct, and that the FCPA Unit is assisted by the Kleptocracy Asset Recovery Initiative, through which prosecutors in the Criminal Division’s Asset Forfeiture and Money Laundering Section and Office of International Affairs pursue ill-gotten riches from corrupt officials using civil authority.  Finally, Ms. Caldwell encouraged prompt self-disclosure of criminal conduct and an appropriately tailored internal investigation of the misconduct, including disclosure of facts regarding individuals responsible for the conduct.  She cited PetroTiger as a “fine example of the kind of cooperation we expect,” where the company self-reported and fully disclosed facts that implicated two CEOs and a top in-house counsel.  Caldwell also cited Marubeni as an example where a company did not self-report and had to face the consequences of the decision not to cooperate.