Assessing the impact of the DOJ’s monitorship policy six months in
By 
Jaclyn Jaeger2025-10-23T20:36:00
It has been nearly six months now since the Department of Justice’s (DOJ) Criminal Division released its memorandum on the selection of compliance monitors. This article provides a critical analysis of the monitorships that received early terminations, those that remain in place, and the broader compliance lessons they impart.
By way of background, the DOJ in May 2025 released two memos directed to all Criminal Division personnel – one memo outlining the agency’s enforcement priorities and policies for prosecuting corporate and white-collar crimes, and the other memo outlining revisions to the selection and use of monitors.
As part of the administration’s lighter-touch enforcement approach, prosecutors are now directed to impose monitors in corporate criminal resolutions only when “necessary,” when a company is struggling to implement an effective compliance program on its own.
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