In our concluding episode in this five-part series, Vin DiCianni and myself discuss proactive monitoring, which demonstrates the benefits of using a third party to fulfill the compliance mandates that have been laid out by the DOJ. Proactive monitoring is directly in the wheelhouse for every compliance program’s three key prongs: prevent, detect and remediate. The Benczkowski Memo and other DOJ pronouncements not only further articulates the road map of what the DOJ expects but also how a company can move through the enforcement process to receive a full declination under the FCPA Corporate Enforcement Program.

For more information on Affiliated Monitors, visit their website at