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Jonathan J. Rusch: Since 1977, with the enactment of the Foreign Corrupt Practices Act, the United States Department of Justice has played a leading role in applying the Act’s anti-bribery, books and records, and internal controls provisions in enforcement proceedings against numerous companies and individuals worldwide. In November 2015, the Department of Justice took the unprecedented step of hiring a Compliance Counsel to guide its prosecutors in decision-making in corporate prosecutions and in benchmarking corporate compliance. This Memorandum is composed as an open letter to the Compliance Counsel, focusing on how she and the Department of Justice should go about that critical benchmarking function.