Credit Suisse Group AG announced a global settlement with U.S., U.K. and Swiss authorities on October 19, 2021. Then, just a little over a week later, Deputy Attorney General Lisa Monaco issued a memorandum to DOJ prosecutors outlining several significant policy changes, including how the DOJ will consider prior misconduct and when it will require a compliance monitor. The timing of Credit Suisse’s settlement seems fortuitous then, coming just days before these policy updates which could have significantly impacted the outcome for a bank that has found itself in hot water multiple times in recent years. In this second article unpacking Credit Suisse’s settlement, we look at whether the bank snagged a good deal considering the underlying conduct and whether it might have fared even worse if its settlement had come a few days later. In the first article about the settlement, we looked at the controls failures that lead Credit Suisse into trouble and how it managed to avoid FCPA charges from the DOJ. See “Credit Suisse Settles Bribery Allegations With SEC but DOJ Focuses on Investor Fraud” (Nov. 10, 2021).