Two former FCPA prosecutors who have moved to the other side of the table recently offered their candid views from the trenches of FCPA enforcement.  They discussed hot topics including whether the DOJ is targeting foreign companies, how international cooperation affects enforcement and how effective the government really is at evaluating compliance programs.  The former prosecutors also opined on the voluntary disclosure calculus, whether the Yates memo will increase individual prosecutions, how companies should “follow the money” to strengthen internal controls, and more.  The panelists, Nathaniel Edmonds, now a partner at Paul Hastings, and Stephen Spiegelhalter, now a principal in the Fraud Investigations & Dispute Services practice at EY, spoke during a panel at the recent SCCE Compliance and Ethics Institute in Las Vegas.