At their April meeting, the U.S. Sentencing Commission voted to adopt changes to Chapter 8 of the Sentencing Guidelines Manual. That chapter defines an effective compliance and ethics program and has been one of the sacred texts of the compliance profession. Here is my summary of the changes: Changes to §8B2.1 In defining an Effective [...]
Tag Archives: Federal Sentencing Guidelines
Making the Case for Compliance at Private Companies
More focus has been aimed at the need for compliance programs at public companies. Of course, that focus has been largely drive by the requirements of Sarbanes-Oxley. The other focus comes from highly regulated industries like financial services that require compliance programs. That doesn’t mean that private companies can ignore compliance. There are many more [...]
Proposed Amendments to Sentencing Guidelines
The United States Sentencing Commission has proposed some changes to the Federal Sentencing Guidelines. Of the eight changes, one should catch the eye of compliance professionals. There is a proposed amendment to Chapter Eight of the Guidelines Manual regarding the sentencing of organizations, including proposed changes to §8B2.1 (Effective Compliance and Ethics Program) and §8D1.4 [...]
Principles of Federal Prosecution of Business Organizations
At last week’s Compliance Week Conference, I saw a paradigm shift in thinking about the factors to be included in a compliance program. Most compliance programs have placed a lot of emphasis on the federal sentencing guidelines. After all, those guidelines give credit for having an effective compliance program. So you want to have an [...]
Your Compliance Program and Enforcement
This session at Compliance Week Conference 2009 was another “dark session” so I am not sharing detailed notes, merely a perspective on some issues that were presented. John Roth, an Assistant U.S. Attorney in the Fraud and Corruption Section shared his insights and Bruce Carton did his best Phil Donahue impression by eliciting questions from [...]
A Benchmarking Survey on Third-Party Codes of Conduct
Rebecca Walker of Kaplan & Walker LLP is the author of a report on A Benchmarking Survey on Third-Party Codes of Conduct (register to download) sponsored by The Society of Corporate Compliance and Ethics. The SCCE received survey results from more than 400 compliance professionals on how they deal with third-party compliance policies. As Rebecca [...]
Assessing Corporate Culture
Ed Petry of the Ethical Leadership Group put together a two part paper on Assessing Corporate Culture: Assessing Corporate Culture – Part I and Assessing Corporate Culture – Part II. [There are] specific steps that compliance and ethics officers can take to begin the process of identifying their organizations’ culture including: • Conduct surveys, focus [...]
An Effective Compliance Program under the U.S. Sentencing Commission Guidelines
Section 8B2.1 of the 2007 version of the United States Sentencing Commission Guidelines define and “effective compliance and ethics program” for purposes of section (f) of § 8C2.5 for the Culpability Score and section (c)(1) of §8D1.4 for Recommended Conditions of Probation – Organizations: (a) To have an effective compliance and ethics program, for purposes [...]
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