Episode 405 - DOJ Balt Declination: Individual Accountability in Action

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.

You can listen to Episode 405 - DOJ Balt Declination: Individual Accountability in Action online on Radio and Podcast. Open the player on this page to stream the available audio.

Episode 405 - DOJ Balt Declination: Individual Accountability in Action is an episode from Corruption Crime & Compliance by Michael Volkov.

This episode is 10:22 long.

This episode was published on Apr 13, 2026.

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