Perhaps the biggest news in U.S. anti-corruption enforcement in 2021 came at the end of October when Deputy Attorney General Lisa Monaco announced four major policy changes in a speech and what has become known as the Monaco Memo. However, after these announcements were made, FCPA enforcement continued to be slow as 2021 limped to a close and 2022 opened, providing few examples of how they might be applied in practice. In this first part of our series taking a close look at the Monaco Memo, we attempt to provide greater clarity on the changes to existing policies on individuals and cooperation. Future articles will address how and when monitors will be required as part of negotiated settlements and the new directive to consider the entirety of a company’s conduct in making charging decisions, as well as what can be expected from the Corporate Crime Advisory Group. For more on DAG Monaco’s policy statements, see “The Accountability Message: What DOJ’s Policy Updates on Corporate Crime Mean for Compliance Officers” (Nov. 10, 2021).