Q&A with former FCPA unit chief Charles Duross on the DOJ’s monitorship policy
By 
Jaclyn Jaeger2025-11-06T19:06:00
In May 2025, Matthew Galeotti, Head of the Department of Justice (DOJ) Criminal Division, issued a memorandum outlining the criteria Criminal Division prosecutors are to consider for imposing and selecting independent compliance monitors in corporate resolutions.
To better understand how the DOJ’s monitorship policy has evolved over the years, what practical implications the new memo has on companies facing Criminal Division matters, and what makes for an effective monitorship, Compliance Week caught up with Morrison Foerster partner Charles Duross, co-head of the firm’s FCPA and Global Anti-Corruption practice.
Duross brings a unique perspective, having overseen 17 monitorships during his four years as Chief of the Fraud Section’s FCPA Unit from 2010-14, in addition to serving as a former compliance monitor for Brazil-based construction and engineering company Odebrecht from 2017 until November 2020.
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