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: U.S. Sentencing Commission
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…
Seven Questions to Ask to Optimize Your Compliance Programs
Compliance Week put on a webinar covering Practical Guidance: Seven Questions to Ask to Optimize Your Compliance Programs. Bruce McCuaig, Vice President, Risk and Compliance and Mike Rost, Vice President, Marketing of Paisley presented. Mike started off with some background of Paisley, then moved onto the “Why?” of Compliance. Companies want to avoid the downside…
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…