In this podcast, James Tillen and Marc Alain Bohn* discuss Miller & Chevalier's FCPA Winter Review 2019, which reviewed the latest data on Foreign Corrupt Practices Act (FCPA) enforcement trends under the Trump administration; the impact of recent Department of Justice (DOJ) policies on companies' anti-corruption compliance programs; and the effect of the General Data Protection Regulation (GDPR) on investigations. "We now have two years' data by which to evaluate FCPA enforcement under the Trump administration," Bohn said. "And so that gives us a little more data to put behind analysis as to where enforcement under the current administration is going, more so than we had in the Review in years past."

Tillen believes the various updates to DOJ policies across 2018 should encourage companies to reevaluate their compliance programs. "We've always been beating a drum of the importance of effective anti-corruption compliance programs," he said. "I think where now it might be an easier sell for some companies internally is because of the recent changes in DOJ policy statements."

*Former Miller & Chevalier attorney