The Trump administration has entered the FCPA enforcement fray by issuing two declination-with-disgorgement letters under the ongoing Pilot Program. The first was for gas supplier Linde in connection with a profit-sharing arrangement between Linde’s newly acquired subsidiary and Georgian officials. The second was for CDM Smith, an engineering and construction company, and resolved issues relating to the bribery of highway officials in India in exchange for contracts. Linde agreed to disgorge $7.82 million and forfeit $3.14 million, and CDM Smith agreed to disgorge $4.04 million. “The Sessions DOJ, through these resolutions, has demonstrated its commitment to the Pilot Program through rewards to companies that timely self-disclose, cooperate, remediate and disgorge profits,” Edward Kang, a partner at Alston & Bird, told the Anti-Corruption Report. See “A Close Look at the DOJ’s New Declination-Plus-Disgorgement Settlement Approach” (Oct. 12, 2016).