The U.S. Department of Justice last summer updated its guidance in the Evaluation of Corporate Compliance Programs, its roadmap for how companies can design and implement programs to steer clear of fraud issues. The new guidance and follow-up comments from officials high up in the Criminal Division have made clear that the DOJ is using sophisticated data tools to monitor the markets, and those companies who have the resources to do so should be keeping an eye on their internal data themselves. If they aren't, the DOJ has made clear the lack of compliance efforts could weigh on any future charging and sentencing decisions.