Raytheon Company (Raytheon) and its parent company, RTX Corporation, recently entered into settlement agreements with several federal agencies with the hefty price tag of $950 million in fines and disgorgement. However, the biggest news was that the companies must retain multiple compliance monitors to ensure that they are following through on the promises they made in the settlements. Imposition of a monitor is a feared outcome for many companies subject to federal investigation as monitors are both expensive and invasive. Yet, they can provide an opportunity: a chance to refresh and elevate a corporate compliance program without much in the way of pushback from money crunchers, naysayers or other internal stakeholders. The first article in this two-part series laid out the many moving pieces that made up the whole of Raytheon’s settlement. This second part shifts focus to the monitorships and the lessons learned from the resolutions for companies in the aerospace and defense industries. See “How to Build a Sustainability Plan After Settling With the DOJ” (Nov. 6, 2024).