Deputy AG Rosenstein Assumes Causation in Calling the FCPA Pilot Program “Successful”

Although Deputy Attorney General Rosenstein characterizes DOJ's FCPA Pilot Program as a success, but there are no public statistics about the number of voluntary disclosures provided to DOJ, nor any evidence those disclosures would not have been made but for the policy. "There are many ebbs and flows to FCPA voluntarily disclosures as well as enforcement actions, and drawing conclusions about most things FCPA related through a mere 18 month window is suspect," says an article on FCPA Professor.