In this article, Daniel Patrick Wendt examines the treatment of merger and acquisition risks in the Department of Justice's revised guidance for corporate compliance programs. "The Department of Justice's revised guidance for prosecutors to use when evaluating compliance programs for companies potentially subject to enforcement actions is a great tool for in-house personnel and external counsel to use in benchmarking programs, but it should not be viewed as an exhaustive list of risk areas," Wendt wrote. "One area that seems to be missing, for example, is merger and acquisition risks when transferring shareholdings, disposing of assets, and/or exiting markets."