Although the election of a president who has disparaged the FCPA has companies curious about the future of the law, DOJ insiders argue that enforcement will continue and so should company compliance efforts. During SCCE’s Annual Compliance and Ethics Institute, Rebecca Rohr, vice president and associate general counsel at Hewlett Packard Enterprise, and former principal deputy chief of the Fraud Section, Paul Hastings’ Nat Edmonds, both former prosecutors, shared their take on how best to protect companies in the shifting enforcement environment. The duo argued that career prosecutors committed to the FCPA, a lack of legislative action and the ongoing trend of international enforcement indicate that U.S. anti-corruption enforcement will continue despite Trump’s stated criticism. They also discussed the ongoing Pilot Program and provided a comprehensive chart of all cases decided since its inception, which is included in this article. See also “Current and Former FCPA Officials Debate Enforcement Trends and Strategies
” (May 24, 2017) and “DOJ Seeks to Reassure on FCPA Enforcement
” (Apr. 26, 2017).