The recently unsealed criminal charges against five individuals for participating in efforts to pay bribes to foreign government officials demonstrate the DOJ’s continued commitment to individual accountability and to cooperation with foreign enforcement agencies. Of note is that four of the five have already entered guilty pleas, but charges against the fifth – a third-party intermediary located outside the U.S. – are both numerous and still pending. Practitioners weigh in on what this means for individual accountability, corporate cooperation, and the perhaps cozy relations between the DOJ and its foreign counterparts. See “Rolls Settlement Illuminates SFO Expectations for Cooperation and Compliance” (Mar. 15, 2017), “SFO Arrives in the Anti-Corruption Premier League With Rolls-Royce Settlement” (Mar. 1, 2017) and “Rolls-Royce Settlement Offers Lessons on How to Pay Commissions Without Corruption” (Feb. 15, 2017).