The InternationalFinanceCorporation (IFC) and the MultilateralInvestmentGuarantee Association (MIGA) established the ComplianceAdvisor/OmbudsmanOffice (CAO) in 2000.
When an audit firm acts as an advisor for compliance monitoring, in particular when they are monitoring their own work as in the JPMorgan foreclosure review case, its difficult to know whose side the firm is really on.