FCPA Settlement Agreements, Monitors and Self Monitoring

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This article explores an apparent trend of the DOJ less frequently requiring Independent Corporate Monitors as part of their settlement agreements (i.e. deferred prosecution agreements, non-prosecution agreements, administrative agreements, consent agreements, etc.) with organizations. It provides some insight into what may be causing this trend and why it is most likely limited to matters concerning violations of the Foreign Corrupt Practices Act. The article also briefly explores the concept of "self-monitoring," where an organization self evaluates and reports on their own compliance with the terms of a settlement agreement with a government agency, and why permitting "self-monitoring" should be approached with great caution by the government.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© John Hanson, Artifice Forensic Financial Services, LLC | Attorney Advertising

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