An alleged international bribery scheme has led to the DOJ declining to prosecute French medical device company Balt SAS and filing an indictment against two employees at the company’s U.S. subsidiary (Balt USA). At the same time, in France, the Parquet national financier entered into the French equivalent of a deferred prosecution agreement with Balt USA. This first article in a two‑part series examines what the declination and indictment reveal about the DOJ’s application of policies issued in the past year, including the Department‑wide Corporate Enforcement Policy issued in March 2026. The second article will look at the extraterritorial reach of the DOJ in FCPA cases, anti-corruption cooperation between the U.S. and France, best practices for mergers and how anti-corruption agencies are prioritizing investigations in the life sciences sector. See “What Does the FCPA EO Mean for European Enforcement?” (Apr. 23, 2025).