In this article, The Wall Street Journal Blog interviews Andrew Farley, General Counsel of KBR, regarding the use of a compliance monitor as a result of a plea agreement. Miller & Chevalier Member Kathryn Cameron Atkinson served as KBR's compliance monitor for three years. "The way the plea agreement worked was: We propose three people to DOJ, and Kate was selected by DOJ. We chose her because our counsel had prior dealings with her. We interviewed her and the other two candidates. We liked her answers, her commitment to compliance and her being reasonable with the company’s money," Farley said, adding that KBR was somewhat price sensitive after seeing what other companies paid for their monitors. "We also liked that Kate was a woman," he said, "and I believe she was the first female monitor appointed by DOJ."

Atkinson worked closely with KBR during her term as compliance monitor. According to Farley, "She was there to prevent a recurrence of the crime for which we were convicted. She was tasked with examining our processes, practices and procedures to basically be in a position at the end of the monitorship to certify to DOJ that we have the necessary processes, practices and procedures in place to prevent activity those similar to that which got us convicted."

"The relationship was professional, cordial," Farley said. "We had differences to resolve, but no major disagreements. She provided good, timely advice that enhanced our policies and procedures. She provided enhancements to what we were doing."