Recent Resolution of Fraud Allegations Signals DOJ’s Increased Use of Corporate Monitorships
On December 21, 2021, the DOJ announced a resolution of its criminal investigations into NatWest Markets Plc, a global banking and financial services firm based in the United Kingdom. Accused of violating the terms of a 2017 non-prosecution agreement, NatWest pleaded guilty to one count of wire fraud and one count of securities fraud, agreeing to pay approximately $35 million in a criminal fine, restitution, and forfeiture. Additionally, NatWest agreed to serve three years of probation, and — most notably — to engage an independent compliance monitor. The imposition of a corporate monitor represents a stark departure from the previous administration’s reticence to employ this costly and often burdensome sanction.
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