Outgoing Deputy Attorney General Rod Rosenstein and Assistant Attorney General Brian A. Benczkowski both delivered public remarks in early March that touched upon familiar themes in relation to FCPA enforcement and corporate prosecutions more generally.  These themes included the front-line role that companies play in detecting and preventing corruption through robust compliance programs; changes made to DOJ’s “anti-piling-on” and corporate compliance monitor policies; and recent efforts by DOJ to increase transparency in its enforcement policies.  In particular, AAG Benczkowski discussed two FCPA declinations, involving Insurance Corporation of Barbados Limited and Cognizant Technology Solutions Corporation.  In both cases, AAG Benczkowski explained, misconduct appeared to reach the highest levels of the company, but the companies promptly disclosed the misconduct, performed a comprehensive investigation, and enhanced their internal controls as appropriate.

Remarks as Prepared (Rosenstein)

Remarks as Prepared (Benczkowski)

FCPA Corporate Enforcement Policy (Updated March 2019)