As initially reported yesterday by the FCPA Professor, there is an invaluable article out, recently published in the University of Pennsylvania Journal Of Business, entitled “Somebody’s Watching Me: FCPA Monitorships and How They Can Work Better” by Gibson Dunn & Crutcher attorneys Joseph Warin, Michael Diamant, and Veronica Root. This article is a ‘must read’ for any attorney working in the Foreign Corrupt Practices Act (FCPA) arena, whether in private practice or in-house counsel.

In a section entitled, “What an Effective FCPA Monitorship Looks Like” the authors posit that the “benchmark for any monitor’s success is fulfilling the terms of the applicable settlement agreements.” The authors identify five key components which help to bring a monitorship to a successful conclusion.