In 2019, nearly 60% of U.S. Department of Justice (DOJ) corporate resolutions in Foreign Corrupt Practices Act (FCPA) cases called for the imposition of an independent compliance monitor. Independent compliance monitors are appointed pursuant to a negotiated settlement, such as a deferred prosecution agreement, with an enforcement agency. The settlement defines the scope and term of the monitorship, which generally spans for several years following the announcement of the resolution.
The DOJ is not the only enforcement agency that relies on monitorships. In June 2019, for example, the New York State Department of Financial Services (NYDFS) solicited applications for a second independent compliance monitor for a financial institution after finding that the institution had failed to sufficiently remediate issues with its anti-money laundering compliance programs during the initial monitor term.
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