Bloomberg Law
April 21, 2022, 6:54 PM

New DOJ Monitorship Shows When Compliance Upgrades Aren’t Enough

Ben Penn
Ben Penn

A waste management company caught bribing overseas officials impressed the Justice Department with “extensive remediation measures” including a new compliance chief and updated internal controls, but prosecutors imposed an independent monitorship anyway.

DOJ’s deferred prosecution agreement with Stericycle Inc. announced Wednesday noted that the company’s new compliance program wasn’t “fully implemented or tested,” making it necessary to appoint a two-year monitor to ensure deterrence of repeat misconduct.

The monitorship is the latest indication the department is following through on Deputy Attorney General Lisa Monaco’s pledge to rely more on an enforcement tool, which fell out of favor in the prior ...