In October of 2021, the Department of Justice (“DOJ”) announced it would ramp up its enforcement against corporate repeat offenders of white-collar crimes and prioritize action against individual actors to promote accountability. The new measures implemented permit the DOJ to consider all prior wrongdoing by a corporation when deciding how to resolve a new investigation. Leniency programs of the past will not be extended to wrongdoers unless all believed participants, whether employees or executives, are disclosed. There has also been a shift from financial penalties to probationary settlements, which require companies not only to admit fault and pay fines but also to improve their monitoring of employees to deter crime. This may require outside monitoring to verify compliance, which can be burdensome and expensive.