You are a member of a legal and consulting team that is representing Maxwell Power, a New York and London-based power and transmission company that builds power plants in the United States, United Kingdom, and other countries in Europe and Asia. Your team has recently been informed that several whistleblowers have anonymously reported the following information through Maxwell Power's confidential reporting hotline:

• Since 2016, several senior company executives have been involved in authorizing the payment of bribes to senior officials in multiple European and Asian countries in order to secure government contracts for powerplant constructions.
• Those bribe authorizations reportedly originated in the United States or were authorized by emails from company officials based in the United States.
• Since 2018, Maxwell Power's Chief Executive Officer, John Hoch, has cut the budget and staffing of the company's corporate compliance team by 80 percent, and reportedly told senior company executives in a 2019 meeting that he had done so because "compliance is overrated, and we can't let a bunch of compliance nerds get in the way of expanding our business."
• Hoch also reportedly ended the company's automated bribery and corruption risk assessment process, calling it "a needless expense at a time when our revenues are seriously down thanks to COVID."

The legal part of the team is now discussing with company officials whether to report the alleged bribe scheme to the U.S. Department of Justice as possible violations of the Foreign Corrupt Practices Act.

The leader of your consulting team, who is not a lawyer, has asked you to a concise memorandum for the rest of the team that outlines the main areas of inquiry that U.S. Department of Justice prosecutors are likely to pursue if and when they open an investigation of Maxwell Energy. Prepare that memorandum, based on the Justice Department's Evaluation of Corporate Compliance Policy. Do not try to summarize every provision in the Evaluation document, but briefly identify the main elements of the document and focus on any specific portions of that document that pertain to the whistleblower allegations listed above