For most companies that discover anti-corruption issues after a merger or acquisition, the ultimate prize is to win a declination from the DOJ. Balt SAS, a French medical device company, achieved that goal but still faces consequences in France. The case illustrates that, even as the DOJ is increasingly likely to decline to prosecute cases that do not fit neatly into the second Trump administration’s enforcement priorities, there are still risks for individuals and corporations, in the U.S. and abroad. This second installment in a two-part series looks at the extraterritorial reach of the DOJ in FCPA cases, anti-corruption cooperation between the U.S. and France, best practices for mergers and how anti-corruption agencies are prioritizing investigations in the life sciences sector. The first article analyzed the DOJ’s handling of the case, discussing how the declination and indictment shed light on new DOJ policies. See “The Changing Landscape of the French ‘Secret Professionnel’” (Apr. 8, 2026).