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Compliance

Built for government scrutiny

An enforcement-grade perspective led by former DOJ leadership, moving beyond paper compliance to ensure operational health and government defensibility.

Target Audience:
Chief Compliance Officers, General Counsel, and Boards of Directors.
Focus Areas

End to end assurance.
No gaps.

01

Program Design & Risk Assessment

Engineering programs aligned with DOJ Evaluation of Corporate Compliance Programs (ECCP) standards.

02

Independent Compliance Review

Subjecting internal programs to the same rigor they would face during a government inquiry.

03

Monitorship & Remediation Support

Guiding firms through corporate resolutions using direct experience from the DOJ monitorship process.

04

Reporting & Investigation

Rapidly assessing whistleblower complaints or internal tips to determine materiality.

05

Code & Policies

Reviewing and creating effective codes and policies

06

Training & Communication

Offering training on key risk areas to targeted audiences

Evidence Snapshots

Short excerpts illustrating how subtle facts become material insights.

Practice Compliance
Signal Type Compliance control degradation
Jurisdiction Jurisdiction-specific
Source Class Regulatory actions & internal controls
RosettiStarr — Intelligence Memorandum Practice: Compliance

Detecting Compliance Program Erosion

Our independent review discovered that while "paper" controls existed, they were systematically bypassed in a high-risk international office.

Urgent need for remediation before
regulatory intervention.

Innovation

Always on the
cutting edge.

Proprietary capabilities applied selectively based on transaction risk, context, and mandate.

Integration

The Enforcement Perspective

Led by Andrew Gentin, former Chief of the DOJ Fraud Section’s Corporate Enforcement and Compliance Unit.

Deep Dive

Enforcement Perspective

Understanding the human driver behind critical decisions.

What it is

Direct insight into how the government evaluates
corporate behavior, applied to your internal controls.

What you get

Defensible work product designed for boards and regulators, built by former government investigators.

Use case

We helped a firm navigate a potential monitor requirement by proactively redesigning their compliance program to exceed DOJ standards prior to a resolution.

Reporting Built for Decisions

What our clients receive is not a report — but a decision tool designed for real-world use.

01

Clear, decision-ready findings

Concise reporting focused on material risks.

02

Substantiated insights

Every claim is supported and traceable.

03

Early risk alerts

Immediate notification when issues emerge.

04

Direct analytical partnership

Ongoing access to the team throughout the engagement

Discuss Your Situation
Confidentially

Discuss Your Situation
Confidentially

Request Consultation

No obligation. Discreet, senior-led discussion.