Law360 (December 7, 2010, 2:57 PM EST) -- As Foreign Corrupt Practices Act enforcement has increased in recent years, the U.S. Department of Justice at the same time has insisted that corporate defendants who voluntarily disclose and cooperate with the government will receive credit and a degree of leniency. In November 2009, Lanny Breuer, assistant attorney general for the DOJ's Criminal Division, reiterated prior agency statements when he insisted that "the department's commitment to meaningfully reward voluntary disclosures and full and complete corporate cooperation will continue to be honored in both letter and spirit."[1] Deputy Assistant Attorney General of the Criminal Division Greg Andres, in an interview conducted by Andrew Weissmann at a compliance conference this fall, noted that the DOJ would be making greater efforts at transparency. Such efforts have now been made and this article analyzes the results....