In this episode, we examine the Department of Justice’s declination in the Balt Medical case—a textbook example of how DOJ is applying its Corporate Enforcement Policy in practice. Despite a multi-year foreign bribery scheme involving payments to a physician at a state-owned hospital, DOJ declined to prosecute the company based on its timely self-disclosure, full cooperation, and effective remediation. But the real story lies in DOJ’s simultaneous prosecution of two individuals who allegedly orchestrated the scheme, highlighting the central role of individual accountability in earning cooperation credit. This episode unpacks how companies must now “connect the dots” for prosecutors—identifying responsible actors and providing actionable evidence—if they hope to secure favorable outcomes.