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Academi to nominate and USAO EDNC retains authority to approve or disapprove in its reasonable discretion. Monitor may, if EDNC agrees, be same person serving as Academi's Special Compliance Officer under prior Consent Agreement.

An individual experienced in foreign trade regulation and, with regard to the external monitor, independent of Academi's corporate structure or ownership.

Monitoring Academi's compliance with the export control laws.

Monitor need not be given access to such portions of Academi's internal documentation, data, and communications protected by the attorney client privilege or work product privilege; however, the assertion of any such privilege shall be noted in the Monitor's twice-yearly written reports and the Monitor's own communications and recommendations shall not be deemed subject to such privileges.

1) Have access to all aspects of Academi's exporting operations, both foreign and domestic, to include the ability to interview any and all officers, directors, and employees, and to review any and all documentation or data, in whatever form.
2) Be required to judge the effectiveness of Academi's export compliance program and record in writing and address all failures and deficiencies and make recommendations for improvement.
3) On a twice-yearly basis, and at least 45 calendar days prior to the scheduled expiration of the DPA, submit a comprehensive written report as to all findings, observations, and recommendations related to Academi's export compliance efforts. Efforts to be made to coincide these reports with those required under Consent Agreement.

Independent of Academi's corporate structure or ownership