In line with the DOJ’s stated focus on transparency, Deputy Assistant Attorney General Matthew Miner elucidated the Fraud Section’s enforcement priorities in a recent speech. He discussed the importance of individual prosecutions, a recognition of big-data analytics as an important part of an effective compliance program and the DOJ’s approach to penalizing companies that are unable to pay the appropriate fine, predicting that there is guidance on that point to come. “While the DOJ has, over time, provided significant FCPA-related guidance to companies (such as with the 2012 FCPA Guide),” John Davis, a member of Miller Chevalier, told the Anti-Corruption Report, “the Department has been consciously and publicly active over the past couple of years in its efforts to, as Mr. Miner says, ‘put ourselves in the shoes of those on the other side of the table’ – companies and their counsel.” See “DOJ’s 2019 Enforcement Activities Demonstrate a Continued Commitment to FCPA Enforcement” (Aug. 7, 2019).