On November 3, 2016, Assistant Attorney General Leslie R. Caldwell spoke at The George Washington University Law School on the DOJ’s Foreign Corrupt Practices Act enforcement efforts.  Caldwell began by stating that, when she began her term as Assistant Attorney General, three areas of particular importance were “to sharpen the focus of our ongoing fight against international corruption,” “to increase transparency in charging decisions with respect to corporate prosecutions,” and “to encourage and foster meaningful corporate compliance and cooperation.”  Regarding ongoing efforts to target international corruption, Caldwell noted that the DOJ Fraud Section is currently adding 10 additional prosecutors to its FCPA Unit, which will increase the size of the FCPA Unit by more than 50%.  Caldwell also stated that the FBI has created three new squads of special agents dedicated to investigating international corruption.  Turning to transparency in charging decisions, Caldwell discussed the one-year pilot program in the Fraud Section’s FCPA Unit, which is “designed to motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section and, where appropriate, remediate flaws in their controls and compliance programs.”  While not sharing precise figures, Caldwell noted that “anecdotally we’ve seen an uptick in the number of companies coming in to voluntarily disclose potential FCPA violations.”  Caldwell further pointed to the DOJ’s DPAs and NPAs as sources of guidance regarding the department’s expectations as to compliance programs.   Caldwell stated: “Companies seeking to measure their own compliance programs need look no further than many of the resolutions we have made publicly available.  There is perhaps no more transparent guidance to a specific corporation than the terms in a DPA or NPA, especially when we set forth remedial or compliance measures we expect.”  Finally, turning to corporate compliance, Caldwell remarked that “it’s increasingly rare to see a case in which a company has a feeble corporate compliance program,” but that, more often, the DOJ encounters “companies with compliance programs that seem strong on paper but are much weaker in practice.”  Caldwell also stated that some companies have not tailored their compliance programs to their businesses, risk-factors, geographic regions, and work.  Caldwell said that compliance programs must be “communicated repeatedly and enforced properly throughout the entire organization” rather than just emphasized in “the executives suites at headquarters.”  Caldwell noted that—in order to help assess whether a given compliance program really works in practice—the Fraud Section has hired a compliance consultant, who is “a former federal prosecutor with extensive compliance expertise in a range of different industries.” DOJ Press Release