Change is here. A few weeks ago, Makan Delrahim – Assistant Attorney General for the Antitrust Division of the U.S. Department of Justice (the Division or DOJ) – signaled a major change in how the Division will assess a company's cooperation. Delrahim explained that "[g]oing forward . . . leniency will no longer be the only benefit" for early detection and reporting of cartel conduct. The Division followed that proclamation with an announcement on 31 May 2019 that it had entered into a deferred prosecution agreement (DPA) with Heritage Pharmaceuticals (Heritage), in part due to the "company's substantial and ongoing cooperation with the investigation to date."