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Expert Analysis

The Future Of FCPA Hybrid Monitorships

Law360, New York (May 15, 2014, 7:10 PM EDT) -- In 2013, four of the U.S. Department of Justice's settlement agreements to resolve Foreign Corrupt Practices Act enforcement actions required independent compliance monitors. In earlier years, these agreements would have required three years of supervision from an independent monitor; instead, three of those four agreements included what have come to be known as "hybrid" monitorships. With hybrid monitorship agreements, the DOJ requires at least 18 months of oversight from an independent monitor, rather than the full 36 months. After the 18-month period, the corporation's compliance requirements shift to self-monitoring and reporting....

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