In recent years, the DOJ has added a requirement to Attachment D in its settlement agreements – companies must develop a sustainability plan that lays out how they will maintain and improve compliance after the settlement obligations come to an end. This article examines how implementing a sustainability plan is instrumental to ensuring a compliance program works in practice and to meeting the obligations of a settlement agreement with the DOJ. It includes insights from experts in the field, including Andrew McBride, Albemarle’s former chief risk and compliance officer and Michael Koenig, JBS’ global chief ethics and compliance officer. See “Meeting DOJ Expectations Post-Resolution Requires Realism and Accountability” (Sep. 11, 2024).