Deferred prosecution agreements (DPAs) are typically preferable to guilty pleas when resolving a corporate criminal investigation, but they come with significant compliance and reporting requirements. In this article, Marc Hennes, Head of Legal Investigations, and Brett Hudson, International Head of Ethics, Risk & Compliance, both at Novartis, along with James Koukios, a partner at Morrison Foerster, reflect on their experiences having been part of the team that worked to ensure compliance with the company’s 2020 DPA. They provide concrete takeaways from three years of compliance enhancements, annual reports and government oversight, as well as the institutional ingredients that make the compliance gains meaningful and lasting. See “Klaus Moosmayer of Novartis Explains Why Holistic Risk Assurance Is the Future of Compliance” (Jun. 23, 2021).