In this article, John Davis discusses the implications of two recent trial wins for the U.S. Department of Justice (DOJ), raising strategy questions for individuals and corporations facing U.S. Foreign Corrupt Practices Act (FCPA) charges in the future. While both verdicts involved cases against individuals, they carry implications for corporations facing their own FCPA-related issues. The DOJ’s evolving Corporate Enforcement Policy (CEP) and other measures "are aimed at increasing the incentives for companies to assist the DOJ in prosecuting culpable individuals – which the DOJ believes sends powerful messages on accountability," Davis said. "Companies are only eligible for declinations under the CEP if they fully cooperate, including providing all available information as to the actions of individuals in the issues under investigation, and such cooperation is further promoted by continuing cooperation mandates in DPAs, NPAs, and plea agreements."