Strengthening cross-border coordination is a growing trend with the development of other countries` enforcement rules. Assistant Attorney General Brian A. Benczkowski said in announcing the Airbus resolution that “the department will continue to cooperate aggressively with our partners around the world to eradicate corruption, especially corruption that harms U.S. interests.  The DPA itself provides a remarkable mix of takeaways in terms of coordination between sovereigns. On the one hand, DOJ revoked its territorial jurisdiction of the FCPA on allegations that Airbus employees and agents sent emails and arranged luxury trips by foreign officials to U.S. sites during their stay in the United States.  On the other hand, in the relevant recitals of the agreement, the data protection authority contains an explicit recognition of the limits of US jurisdiction by the DOJ: “The company is neither a U.S. issuer nor a national company, and territorial jurisdiction for corruption is limited; Although the interests of the United States are so important that a solution is warranted, the interests of France and the United Kingdom in the conduct of the company related to corruption and the judicial basis of a solution are much stronger, and the [U.S. government] has therefore deferred France and the United Kingdom to justify their respective interests, as they deem appropriate[.]  It will be interesting to see whether future intermarital resolutions (or even U.S.
resolutions) contain similar statements about the limits of U.S. territorial jurisdiction or their narrower interests of the prosecutor under the FCPA. In recent years, the standard disclosure requirement has expanded, from the requirement to provide only “credible evidence” in the event of a breach of status, to the disclosure of “all evidence or allegations” of all potential criminal activity, whether inconsistent with the underlying conduct of the agreement and whether or not it is based on a credible allegation. For example, this year`s NPA requires Hapoalim Bank to disclose “all evidence or allegations of a violation of U.S. federal law.”  For Pentax Medical Co., “all credible evidence of criminal conduct or gross misconduct by the company [and its related companies]” would be the source of the reporting obligation.  Depending on how this language is interpreted, it could be a significant – and tedious – intrusion into corporate compliance functions. Instead of expecting companies to self-report truly relevant issues after reasonable follow-up, the DOJ is increasingly asking for all reports so that it can decide for itself what is relevant and what is not. In accordance with the agreement, which has a duration of three years, the distributor has consented to an annual independent audit of its activities and books as well as an independent review for the duration of the agreement.  The distributor has also agreed to take corrective action, including training staff in ethics and changing its policies and procedures regarding the integrity of its company-wide ethics and compliance program.  December 20, 2019, the SFO has announced a DPA with the “G-llp” (“G-llp”), a manufacturer of seismic instruments, to clarify allegations of (1) conspiracy for corrupt payments and (2) non-corruption by employees, both of which stem from alleged corrupt payments to a South Korean official between 2002 and 2015.  The SFO announced the agreement after the founder and two former executives of Gralp were acquitted of conspiracy charges for corrupt payments after a ten-week trial.