Many of the elements of the DOJ’s FCPA Pilot Program have now been codified in the U.S. Attorney’s Manual, Deputy Attorney General Rod Rosenstein said during a speech at ACI’s 34th Annual International Conference on the Foreign Corrupt Practices Act. However, the new DOJ FCPA Corporate Enforcement Policy also includes some significant changes and enhancements to the Pilot Program. The Anti-Corruption Report spoke with various FCPA counsel to take a close look at what has changed, what has not and what companies should expect from DOJ enforcement going forward in this three-part article series. See our series on the Fraud Section’s Pilot Program:  “Going Deep” (Apr. 20, 2016); “How Will the Program Change Voluntary Self-Reporting?” (May 4, 2016); and “Earning Cooperation Credit” (May 18, 2016).