It is striking to note that this year, none of the 17 companies that conducted DOJ investigations with NPAs and DGP voluntarily disclosed the allegations of misconduct, and only two companies – both runaways with abnormally extantuating circumstances – did not receive an ANPA. Among the outliers is Alutiiq International Solutions, LLC (“AIS”), whose NPA referred to the fact that: that AIS`s profits are directly intended to support Indian shareholders, residents or descendants of residents of economically disadvantaged Alaska Native villages, see the Non-Proliferation Agreement, Alutiiq International Solutions, LLC (June 8, 2020), 1 (g) [hereafter “Aliquti NPA” and Bank Hapoalim.M. (“BHBM”) and Bank Hapoalim (Switzerland) AG (“BHS”), the NPA`s allegations of money laundering in coordinated comparisons with unrelated tax infringement allegations that led to a DPA for BHBM and settled an admission of guilt for BHS, see press release, U.S. Dep`t of Justice, Israel`s largest bank, Bank Hapoalim, admits to conspiring with U.S. taxpayers to conceal assets and income in offshore accounts (April 30, 2020), www.justice.gov/opa/pr/israel-s-largest-bank-bank-hapoalim-admits-conspiring-us-taxpayers-hide-assets-and-income (`BHBM Tax Press Release`). One of the corrective measures to be taken in the BHBM case was to ensure that BHBM leaves its private banking activities outside Israel and closes all guilty subsidiaries and subsidiaries, including Latin American subsidiaries and representative offices throughout Latin America, and its subsidiary in Miami, Florida. See non-persecution agreement, Bank Hapoalim B.M. and Hapoalim (Switzerland) AG criminal investigations (April 30, 2020), www.justice.gov/opa/press-release/file/1272446/download [`BHBM and BHS NPA`). BHBM and BHS also agreed to close BHS and sell their banking license, and NPA found that BHS was in the process of closing its operations. Id. The extreme measure of the company`s effective exit may have weighed in favour of an unusual leniency communication in the context of this year`s agreements.  Press release, U.S.
Dep`t of Justice, Chipotle Mexican Grill agrees to pay a $25 million fine and enter into a late prosecution agreement to resolve foodborne outbreak charges (April 21, 2020), www.justice.gov/opa/pr/chipotle-mexican-grill-agrees-pay-25-million-fine-and-enter-deferred-prosecution-agreement (`Chipotle Press Release`).