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Last month, Medtronic Inc. announced that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) would be closing their Foreign Corrupt Practices Act (FCPA) investigations of the medical device-maker without pursuing any charges or an enforcement action. Like most declinations, there is little information regarding what factors the government considered in deciding it would not pursue any action. Looking across a number of recent cases and pronouncements, however, companies can identify certain factors which undoubtedly will play a role in determining whether a company will weather an FCPA or anti-bribery investigation without facing any further government action.