How to Prepare for a Monitorship
Companies that have violated the Foreign Corrupt Practices Act of 1977 (“FCPA”) or similar international compliance rules and regulations are more and more facing so called deferred or non-prosecution agreements (“DPAs” or “NDAs”). Next to monetary fines, DPAs or NDAs often impose a duty on the delinquent company to hire an independent compliance monitor, who assesses the different elements of the company’s compliance program. Pohlmann & Company has gained extensive experience and insight into those requirements themselves, from both the company’s and the monitor’s perspective.