While the U.S. has often been heralded as the driving force behind the increase in anti-corruption enforcement, Daniel Kahn, Chief of the DOJ’s FCPA Unit, recently insisted that his country cannot “take credit for the tremendous work that everyone is doing and the sea change that has happened.” Speaking at the International Bar Association’s Anti-Corruption Conference in France, he argued that it is efforts across the globe that are changing the enforcement landscape. “At a panel like this five years ago, you would have heard people saying the right thing,” he remarked, but things were still moving slowly. Now, enforcers all over the world, such as his co-panelists Paulo Galvão de Carvalho of the Brazilian Federal Prosecution Office and María Laura Roteta of Argentina’s Ministerio Publico Fiscal, are actively pursuing corrupt officials and companies. Galvão de Carvalho is one of the prosecutors working on the Petrobras investigation. See “Adapting Company Compliance Policies to Account for Recent Political Changes in Argentina and Chile
” (May 2, 2018).