An agreement with the government to resolve an investigation may require the corporation to appoint an independent compliance monitor to review and evaluate the corporation's compliance with its remedial provisions and to recommend compliance program improvements. 1 When a monitorship is included as a term of a deferred prosecution agreement (''DPA'') or nonprosecution agreement (''NPA''), typically the corporation is required to retain the monitor at its own expense for an extended period, and the monitor is required to report periodically to the government in writing on the company's progress.2
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Originally published in the March 25, 2014 edition of Bloomberg BNA's The United States Law Week, 03/25/2014.
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