John Davis, Coordinator of Miller & Chevalier's FCPA & International Anti-Corruption practice, commented on the Department of Justice's (DOJ's) revised Foreign Corrupt Practices Act (FCPA) Enforcement Policy, which was announced by Deputy Attorney General Rod J. Rosenstein on Nov. 29. The new policy will be incorporated into the U.S. Attorneys Manual. "A very quick review of [Rosenstein's] speech suggests that the new policy could result in more declinations," said Davis. "But, in my view, the devil will be in the details" regarding how voluntary disclosure, cooperation and compliance improvements, or remediation, are defined, he said, adding that a key question will be whether the definitions of those terms previously in force will change.