The Department of Justice this week gave chief compliance officers and in-house counsel its own version of a Halloween fright, announcing several significant changes to its enforcement policies—from new expectations about the disclosure of non-privileged information to the evaluation of recidivist companies to an even higher likelihood of settling companies receiving a corporate monitor.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...