A flurry of recent FCPA declinations has left some practitioners wondering whether these quiet resolutions are emblematic of a less aggressive approach to FCPA enforcement by a still-young Trump administration. The Anti-Corruption Report talked to practitioners about the significance of declinations obtained by IBM, MTS, Net1, Newmont Mining and Vantage; how these resolutions are related to the Pilot Program, which is currently under review; and the implications for other corporations. See also “First FCPA Actions Under Sessions’ DOJ Are Declinations With Disgorgement” (Jul. 19, 2017).