Imposition of an independent compliance monitor is one of the most dreaded outcomes for companies facing a DOJ investigation. While paying a fine or improving a compliance program may be expensive and burdensome, the company ultimately has some control in the matter. Monitors, on the other hand, “can create an adversarial relationship with the companies they monitor, impose significant expense, stray from their core mission, and unduly interfere with business,” DOJ Criminal Division Head Matthew Galeotti stated when announcing a memo changing when monitors will be required and how they will be regulated. This article, with insights from defense counsel and former DOJ prosecutors, examines these revisions, Galeotti’s statements about the changes, and what they might mean for companies facing Criminal Division investigations going forward. See “Adelle Elia of LBI Offers Insights on Working Effectively With a Monitor” (Jul. 24, 2019).