Welcome back to bribes swindler steel. I'm Alexandra Rage, and my guest today is Chuck de Ross,

who heads Morrison Forster's Global Anti-Bribery Practice, where he has overseen Foreign

Crop Practices Act investigations relating to business in more than 50 countries.

Prior to joining the firm, Chuck served as a deputy chief in the DOJ's fraud section, where he led the FCPA unit and was in charge of all of the DOJ's FCPA investigations, prosecutions, and resolutions.

Today we're talking about how companies and people get caught after they engage in

bribery.

And Chuck is the right man for this job.

Trace member companies will also know Chuck is a regular speaker at Trace events,

and he never disappoints.

So with that, Chuck, thank you for joining me.

Wow, no pressure.

Okay.

So you've talked a lot about how it is that

companies get caught, and I think that's an area of perennial interest to those practicing in this

field. But why do you start not with companies, but with individuals? There's a new focus on

individuals that you've talked about a little bit. Why is that

relevant? I mean, apart from to the individuals themselves. Well, it's certainly been something

DOJ has been focused on for quite some time. But I think just in the past couple of years,

if you were to look at the track record that DOJ has, they really have focused on increasing the number of individuals

being prosecuted, both investigated and then ultimately either through guilty pleas or convictions

at trial. The DOJ, I think, has been fairly aggressive on that front. And you see it, I think,

in multiple ways. One, you see it in terms of their policies. So previously the pilot program,

...