In this episode, Douglas Zolkind (Debevoise & Plimpton and former Assistant U.S. Attorney for the Southern District of New York who prosecuted FCPA trials involving Ng Lap Seng and Patrick Ho): (i) shares his experiences trying FCPA cases including the difference between “FCPA violations” and “FCPA violations that can be proven at trial”; (ii) discusses underappreciated aspects of DOJ FCPA enforcement; (iii) opines whether the government is vulnerable on some of its FCPA enforcement theories; and (iv) suggests a change to FCPA enforcement.