On July 11, 2019, Assistant Attorney General Makan Delrahim announced fundamental and sweeping changes to the Division’s approach to corporate compliance policies that will bring it into line with other Department of Justice branches. In every case, the Division will now consider compliance programs in deciding whether to file criminal charges and in calculating fines. Also, when a company faces charges, Division prosecutors may now consider proceeding by way of deferred prosecution agreements (DPAs) rather than requiring companies to plead guilty. These policy shifts could be the most significant changes to U.S. criminal antitrust enforcement since the Division adopted its Corporate Leniency Policy more than 25 years ago. This Covington Alert will discuss how the policy change departs from longstanding DOJ practice, the significance of the change to corporations that face potential risk in cartel investigations, and the many unanswered questions about how the DOJ will apply the policy.