In this episode, Robert Luskin (Paul Hastings) elaborates on his previous comments that foreign corporations in FCPA inquiries have real concerns about “whether U.S. lawyers are really defense lawyers or former prosecutors in a better suit” and how some FCPA practitioners are not willing to be adverse to the DOJ; (ii) discusses legal and policy issues present in FCPA actions against foreign companies; and (iii) opines whether the FCPA has been successful in achieving its objectives