important question of whether or not monitorships actually achieve their
an initial exploration into how monitorships actually work in practice.
Based on interviews with those involved in monitorships and on
leads to monitorships that are significantly less ambitious than
recommendations for reforms to help ensure that monitorships are crafted
The DOJ has imposed at least 44 monitorships as part of
has often participated with the DOJ in its monitorships, (14) along with
longer history with monitorships that has evolved over time.
brief history of monitorships and how they have evolved over time in
provide a lens through which to view the current use of monitorships.
Corporate monitorships have a direct history in public law
Somebody's Watching Me: FCPA Monitorships and How They Can Work Better, 13 U.
However, there is also a need for flexibility to tailor a monitorship to the specifics of a company and its particular organizational environment.