governing monitorships is often the monitor's self-interest in
of a lucrative monitorship on John Ashcroft's firm).
1713 (2007); Cristie Ford & David Hess, Can Corporate Monitorships Improve Corporate Compliance?, 34 J.
Only 108 companies have been subject to monitorships between 2008 and 2014.
reports for the duration of the monitorship. (310) Recently, companies
the monitorship commences." Morford Memo, supra note 282, at 7.
Do: Appoint an internal point person to manage the monitorship
Concerns about privilege may be addressed in limited waiver and confidentiality agreements with the monitor to ensure that the company receives notice and an opportunity to oppose any third-party requests to the monitor for company information learned during the course of the monitorship.
Joseph Warin et al., 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.
The use of corporate monitorships as part of settlement agreements
Some argue that settlement agreements with monitorships are a
He further has particular and extensive experience in conducting corporate compliance monitorships
and compliance program evaluations, including in matters before domestic, foreign, and multinational regulators, as well as in assisting American and European clients in designing, administering, and maintaining anti-corruption programs.