In what he described as “another step towards greater transparency and consistency in corporate enforcement,” Deputy Attorney General Rod Rosenstein recently announced a new DOJ policy designed to reduce “disproportionate enforcement of corruption laws by multiple authorities.” When bringing corporate cases, “the Department,” Rosenstein stated in a memo distributing the policy, “should consider the totality of fines, penalties, and/or forfeiture imposed by all Department components as well as other law enforcement agencies and regulators in an effort to achieve an equitable result.” The Anti-Corruption Report spoke with former DOJ prosecutors about the impact the new policy will have on anti-corruption enforcement. See our three-part series on the DOJ’s FCPA Corporate Enforcement Policy: “What’s New and What’s Not” (Jan. 10, 2018); “How Important Is the Presumption of Declination?” (Jan. 24, 2018); and “Cooperation and Compliance Expectations” (Feb. 7, 2018).