Investors and targets generally view cross-border transactions from a risk-based perspective. That calculus applies not only to the manner in which an investment is made, but also to the level of diligence conducted, the timing for closing the deal, and the regulatory filings that need to, or should, be made to close the transaction effectively. This risk-based approach has been a baseline for how diligence has been and continues to be conducted for cross-border transactions. In September 2022, however, that calculus may have been brought to the forefront as part of the Department of Justice’s (DOJ) overall policy emphasis on corporate compliance. Deputy Attorney General Lisa Monaco, followed by Assistant Attorney General for the Criminal Division Kenneth Polite, and Principal Associate Deputy Attorney General Marshall Miller seemed to raise the bar by highlighting DOJ’s focus on post-acquisition remediation when violations or noncompliance were identified during the diligence process.1 Miller’s comments from his September 20, 2022 keynote speech at the Global Investigations Review conference provide insight into how DOJ views post-acquisition remediation and appropriate diligence levels...