# Compliance Monitor > [!note] Stub > This is a short entry that hasn't been fully written yet. An outside party installed under a corporate criminal resolution to verify that the company actually builds the compliance program it promised. The monitor is **selected in consultation with the Department of Justice, paid by the company, and reports to the Department** — not to a court. Nothing makes a monitor an officer of the court, and in [[United States v. HSBC Bank USA]] the Second Circuit held that a monitor's report is not a judicial document and need not be unsealed. Monitors are the only mechanism in the resolution toolkit that produces independent verification rather than a promise, which is why their availability is the sharpest indicator of how demanding a given enforcement posture is. The Criminal Division's memorandum of 12 May 2025, "Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime," states that monitors "must only be imposed when they are necessary," that monitorships "must be narrowly tailored," and that the Division reviewed every existing monitorship for continued necessity and ended several agreements early. The Department-wide [[Corporate Enforcement and Voluntary Self-Disclosure Policy]] of March 2026 goes further for its mandated tier: in those cases the Department shall **not** require a monitor at all. ## See also - [[Corporate Enforcement and Voluntary Self-Disclosure Policy]] · [[Deferred and Non-Prosecution Agreement Crosswalk]] - [[Deferred Prosecution Agreement]] · [[Non-Prosecution Agreement]] - [[United States v. HSBC Bank USA]] · [[Justice Manual]] · [[Department of Justice]] - [[Canceled Corporate Enforcement]] · [[Regulatory Capture]]