In two recent FCPA-related settlements in the medical devices industry in February and March 2013, and in the manufacturing industry in October 2013, DOJ adopted a "hybrid" approach to monitoring. The DPAs entered in each settlement imposed a compliance monitorship whereby the company must retain an independent monitor for an 18-month period and then self-monitor and report its compliance with the agreement for the remaining 18 months of the DPA.… Continue Reading