Anti-corruption enforcement over the last decade has changed significantly because of the ever-increasing sophistication of the prosecutors in the DOJ’s elite FCPA Unit. These prosecutors have become expert at uncovering corruption and fluent in the language of compliance which has significantly shifted the tenor and content of settlement discussions. The Anti-Corruption Report spoke with recent FCPA Unit alum Tarek Helou and veteran defense attorney Jeffrey Lehtman, both now partners at Wilson Sonsini, about how the settlement negotiation process has changed in recent years. In this first part of our conversation, they discuss the logistics of negotiations, the importance of building trust with the prosecutors involved and how to reach a final deal. The second part will take a close look at the presentations companies are expected to make to the DOJ at the end of an investigation. See “FCPA Enforcers Tout Transparency, the Defense Bar Responds” (Dec. 11, 2019).