As part of the AFN, AIS agreed to pay more than $1.2 million in compensation to the GSA.  The agreement has a unique factor because of AIS Afognak`s parent status as Alaska Native Corporation. With respect to the NPA, doJ considered that almost all of Afognak`s 1,200 shareholders live or descend from two Alaskan indigenous peoples, considered to be struggling municipalities, and that “Afognak uses all of its net income for the benefit of its shareholders,” including providing social programs and supporting aid such as assistance to the elderly and education assistance.  This resolution emphasizes the importance of demonstrable collateral consequences. The agreement resolves accusations that, starting in 1999, FCS conspired not to compete with other companies to offer chemotherapy and radiation therapy to cancer patients in southwestern Florida.  The resolution was conducted as part of a broader investigation into contract allocation and other anti-competitive practices in the oncology industry, conducted by the Department of Understanding and the FBI Tampa Field Office.  In 2020, DOJ continued its practice of requiring companies contracting DPAs and PDAs to extend compliance programs. Often, as is the case in FCPA resolutions, agreements dictate long and detailed reference requirements for business compliance.  To enforce these requirements, DOJ relied heavily on Dieself`s report, which generally includes a company that provides detailed annual reports on corrective actions taken. After a downward trend in recent years, the DOJ has not yet set up independent compliance monitors this year. However, on the issue of the merger of practice, the Crown requested the continuation of a “monitoring organization” for the District of Vermont.  The U.S.
Attorney`s Office for the District of Massachusetts also required an “in-house” monitor as part of a subsidiary plea agreement under the NiSource DPA described above.  However, different legal practices, including different levels of protection for communication between lawyers and their clients, can also complicate negotiations with several regulators. The international rules of the CCA differ from those in the United States in that VPDs are often available only to corporations, are limited to certain offences and are subject to significant judicial oversight. In addition, international regulatory authorities may impose restrictions on cooperating companies that complicate negotiations in the United States. For example, in 2019, the SFO has published new guidelines on what companies should do to obtain cooperation credits in the ENFORCEMENT pricing decisions.  The guidelines outline steps similar to those of the Federal Prosecutor`s Office`s Justice Manual of Economic Organizations, with some important differences. The SFO guidelines state that a company cannot receive any cooperation credit unless it waives the right to witness accounts, notes and transcripts it received during the company`s investigation.  On the other hand, the Court Manual states that prosecutors should not seek exemptions from privileges in corporate criminal prosecutions.
 It remains to be seen how this difference will be made in joint investigations by the DOJ and SFO and whether companies in both countries will be able to cooperate without giving up cooperation credits from either agency. On the contrary, they could put enormous pressure on companies to waive the privileges of sensitive internal investigative equipment in the United States in order to fully meet the expectations of British cooperation.