Michael Peregrine was interviewed by Corporate Board Member (Dec. 11) concerning the Justice Department's increased effort to hold individual directors accountable for bad corporate behavior. "This is not the beginning of some broad effort by the government to seek strict liability for every possible violation of law," Mr. Peregrine stated, but he added that "on certain types of civil or criminal matters the government is definitely seeking to hold individuals responsible through...strict liability principles." Mr. Peregrine advised corporate boards to "be prepared for an increase in the level of reporting up the ladder of potential violations of the law by corporate employees to come to the general counsel's attention," adding that for effective compliance programs, "boards and senior leadership can take steps to make sure that the tone at the top is clear and unambiguous, that education is strong, and that compensation is structured for compliance."