On April 5, 2016, the Department of Justice (“DOJ”) introduced a yearlong “Pilot Program” to guide the conduct of investigations and prosecutions pursuant to the Foreign Corrupt Practices Act (“FCPA”). Announced by Assistant Attorney General Leslie Caldwell, the Pilot Program seeks to bring “transparency” to FCPA investigations and “accountability” to the subjects of those investigations. In the weeks following the announcement, commentators questioned whether the Pilot Program could satisfy its dual objectives. The DOJ then issued two declination letters pursuant to the Pilot Program, demonstrating, for the first time, the tangible benefits available through compliance with its provisions.