Some companies do end up praising the  monitor system. The three-year monitorship for KBR Inc. worked out well from the company’s standpoint, according to general counsel Andrew Farley, though he admits that he was indeed leery at first. “Obviously, having a monitor is an unwelcome experience, but we embraced it,” Farley says.

The government charged that KBR, the Houston-based engineering giant, along with Halliburton Company (the parent of KBR’s predecessor, Kellogg, Brown & Root Inc.), had channeled $180 million in bribes to Nigerian government officials to obtain business contracts worth $6 billion [“The Secrets of Bonny Island,” Focus Europe, Fall 2011]. In a February 2009 FCPA settlement KBR consented to a three-year monitorship, as well as to a $400 million fine. Former CEO Albert Stanley pled guilty to bribery charges this past February and was sentenced to two-and-a-half years in prison.