Core Points - The Boeing Corporation's experience with Deferred Prosecution Agreements (DPAs) illustrates the complexities and uncertainties surrounding federal criminal investigations of corporations, particularly regarding prosecutorial discretion and judicial review [1][2][22] - The 2021 DPA required Boeing to implement a compliance program and pay significant penalties, but subsequent events raised questions about Boeing's adherence to the agreement [4][8][12] Summary by Sections Deferred Prosecution Agreement (DPA) - In January 2021, Boeing entered into a DPA to resolve a conspiracy charge related to the 737 Max crashes, which resulted in 346 deaths due to a concealed software flaw [3] - The DPA included a three-year term, a criminal penalty of $243.6 million, $1.77 billion in compensation to airline customers, and $500 million to victims' families [4] Compliance and Legal Proceedings - Boeing faced scrutiny over its compliance program, with the Justice Department determining in May 2024 that Boeing had breached the DPA by failing to implement an effective compliance program [8][12] - Following the breach, Boeing agreed to plead guilty and accept additional penalties, but the terms of the new deal faced objections from victims' families [9][10] Non-Prosecution Agreement (NPA) - In May 2025, the Justice Department announced an NPA with Boeing, requiring continued improvements in compliance and additional financial compensation to victims [11] - The NPA marked a shift in the Justice Department's approach, moving away from requiring an independent compliance monitor, citing Boeing's progress in compliance efforts [13][15] Judicial Oversight and Victim Advocacy - The court's ability to oversee prosecutorial discretion was limited, as demonstrated by Judge O'Connor's ruling to grant the government's motion to dismiss despite concerns over accountability [19][22] - The role of victims and their advocates has grown, influencing legal proceedings and highlighting the complexities of corporate criminal enforcement [22]