An independent monitorship is an arrangement in which a qualified third party is appointed to assess whether an organization is meeting the terms of a settlement, plea agreement, court order or regulatory resolution, and to report on remediation.
Monitorships
Independent Monitorships + Corporate Compliance Oversight
Guidepost Solutions is a global firm that serves as independent monitor and compliance advisor, and our monitorship practice is a market leader. We act as or support the independent monitor following a criminal prosecution or civil regulatory settlement, and we also provide annual independent reviews for regulated industries such as financial services and healthcare. Our specialties are compliance risk advisory, antitrust, corruption, bribery, forensic accounting, financial crime, cross border investigations and healthcare fraud matters, supported by our investigations, cybersecurity and security consulting teams across regulated and reputation sensitive sectors.
Our team has been appointed multiple times by the US Department of Justice, FinCEN, the US Securities and Exchange Commission and the Commodity Futures Trading Commission as independent compliance monitor. We have also completed several monitorships of global banks in the past 10 years. We provide trusted oversight for organizations operating under government appointed, court appointed and voluntary monitorships. Our professionals include former federal prosecutors, compliance officers, regulators, forensic accountants and corporate governance experts who have successfully served as independent compliance monitors and helped organizations implement lasting compliance reforms.
Our monitorship experience spans financial services, life sciences, healthcare, technology, construction and energy, addressing obligations including anti bribery and corruption (FCPA), anti money laundering (AML), sanctions, antitrust, data privacy and export controls. We also advise companies under active monitorships, helping them meet regulatory expectations efficiently and sustainably.
What is an independent monitorship?
An independent monitorship is an oversight arrangement in which a qualified third-party, the monitor, is appointed to assess whether an organization is meeting the terms of a settlement, plea agreement, court order or regulatory resolution. The monitor evaluates the compliance program, tests whether controls work in practice, reports findings to the appointing authority and the organization, and tracks remediation until the obligations are met.
Monitorships can be imposed by government action or entered into voluntarily. You may also see the role called an Independent Consultant, Independent Compliance Monitor or Integrity Monitor. The work is the same: objective, evidence based assessment that regulators can rely on and that gives the organization a clear path forward.
Types of monitorships we perform
Members of our team have been performing monitorships involving entities in the corporate, nonprofit and construction sectors for more than three decades. These monitorships have involved overseeing divestitures and ensuring compliance with federal and state laws.
- Banking + Financial Monitorships. Independent monitors for banks and financial institutions on AML, BSA and sanctions matters, including several monitorships of global banks in the past 10 years.
- Corporate Integrity Monitoring. Oversight of corporate compliance and ethics programs following enforcement actions or as a condition of settlement.
- Regulator Responsive Monitorships. Independent oversight designed to address regulator concerns and demonstrate remediation to the authorities.
- Construction Monitoring Services. Integrity monitoring for construction projects, contractors and public works programs.
- Transactional Monitoring for Divestiture and Antitrust. Monitoring of divestitures and antitrust remedies to confirm compliance with the terms of the transaction.
Our Monitorship Services Include:
- Serving as court-appointed or government-appointed monitors in enforcement matters
- Conducting independent assessments of compliance programs and controls
- Designing and implementing remediation plans to enhance ethics and governance
- Acting as third-party monitors for voluntary compliance improvement initiatives
- Providing cost-sensitive, scalable oversight solutions tailored to the size, structure, and complexity of each organization
A Practical and Efficient Approach
Guidepost Solutions delivers the same level of rigor and independence expected by regulators—paired with an efficient, right-sized approach that reflects the practical needs of our clients. Our structure allows us to deploy senior experts strategically, ensuring that oversight and remediation efforts remain thorough, transparent, and mindful of resources. We combine investigative, compliance, and operational expertise in one integrated team, enabling clients to achieve full compliance readiness.
Court-Appointed Monitorships
We have had numerous court and other appointments to monitor the conduct of organizations and have received monitorships from or with the approval of the following. Our team has been appointed multiple times by the US DOJ, FinCEN, the US SEC and the CFTC as independent compliance monitor. Over the past 10 years we have also completed several monitorships of global banks.
Federal agencies and courts
- U.S. Department of Justice
- U.S. Securities and Exchange Commission
- Commodity Futures Trading Commission
- Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
- U.S. Department of Treasury, Office of Foreign Assets Control
- U.S. Department of Commerce, Bureau of Industry and Security
- Occupational Safety and Health Administration
- U.S. Attorney’s Office for the Southern District of New York
- Chicago Federal Court
State authorities
- Attorney General of the State of New York
- Attorney General of the State of New York Medicaid Fraud Control Unit
- Attorney General of the State of California
- New York State Department of Financial Services
- New York State Department of Environmental Conservation
- New York State Organized Crime Task Force
- New York State School Construction Authority
- New Jersey Department of the Treasury
Local and municipal authorities
- Manhattan District Attorney’s Office (Office of the District Attorney of New York County)
- New York City Department of Investigations
- New York City Economic Development Corporation
- New York City Transit Authority
- Port Authority of New York and New Jersey, Office of Inspector General
Recent and notable monitorships
- Global banks. Our team has completed several monitorships of global banks in the past 10 years.
- New York City Housing Authority. Bart M. Schwartz was selected by the HUD Secretary in 2019 as federal monitor to ensure compliance with the agreement among HUD, New York City and NYCHA.
- JFK International Airport Redevelopment.
- Magellan Diagnostics Independent Monitor.
- Michigan State University Institutional Assessment and Responsive Action.
- Empire/Liberty Safety and Compliance Review.
Thought leadership in monitorships
Guidepost Solutions’ experts Bart M. Schwartz and Andrew O’Connell contribute their expertise to the Global Investigations Review’s Guide to Monitorships – Fourth Edition.
Their chapter, “When Enforcement Agencies Should Decide to Appoint a Monitor,” explores:
- Mechanisms for imposing monitors
- Types of monitorships
- Agencies that impose monitorships
- DOJ guidance on monitors and the selection process
This contribution underscores Guidepost Solutions’ thought leadership in compliance oversight, government-appointed monitorships, and corporate remediation programs. Read the chapter here: When enforcement agencies should decide to appoint a monitor – Global Investigations Review
If your organization is facing a monitorship, a regulatory resolution or a need for independent oversight, our team can help.
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Listen to PodcastFrequently Asked Questions (FAQs)
Monitors are imposed by enforcement agencies, courts and regulators, and some are retained voluntarily. Our team has been appointed by the US DOJ, FinCEN, the US SEC and the CFTC, along with state and local authorities.
We perform banking and financial, corporate integrity, regulator responsive, construction and transactional monitorships, including divestiture and antitrust matters, as well as voluntary independent reviews.
Yes. Our team has completed several monitorships of global banks in the past 10 years, and we regularly assist financial institutions with BSA/AML, sanctions and compliance program effectiveness.
Selection depends on the appointing authority. DOJ has issued guidance on monitors and the selection process, a subject our experts address in their chapter in the Global Investigations Review‘s Guide to Monitorships.
A monitorship is imposed through government or court action. A voluntary review is retained by the organization, often annually or for self-motivated remediation. We apply the same rigor to both.
MSU Institutional Assessment + RAMAGELLAN MonitorshipEmpire/Liberty Review