In May 2025, the Department of Justice (“DOJ”) announced changes to its corporate enforcement policies, including revisions to the Criminal Division’s standards for the selection and use of monitors. Aligned with the revised standards for the selection and use of monitors, the DOJ conducted a review of all Criminal Division corporate monitorships. Further, companies appeared to report that they did not believe that the monitor was adequately motivated to effectively achieve the company’s compliance objectives. With potentially competing aims of monitors prolonging their services and efficiently satisfying compliance milestones, the Criminal Division’s assessment of corporate monitorships suggests that the imposition of compliance monitors may not, overall, be worth their cost. Key Takeaways