In this episode, Jay Rosen and myself take a look at the line drawn from the Yates Memo to the hiring of Hui Chen, to the Pilot Program, the 3 enforcement actions since then and conclude that FCPA enforcement is changing. Jay reviews what companies need to consider in their investigation protocols in light of this new enforcement era. We also shout out to Dan Chapman the new CCO at Vimpelcom and Pat Stokes who recently announced a move to Gibson Dunn. I explain how Harry Potter informs your whistleblower program.