The Time is Now to Amend the US Sentencing Guidelines on Corporate Ethics and Compliance Programs

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  1. August 14, 2015

    […] This media blow up is a teachable moment for compliance programs.  There are seven elements of a compliance program, as outlined by the Federal Sentencing Guidelines.  Those seven elements speak to a program that promotes ‘compliance with the law’, detects ‘criminal conduct’, and is within the purview of the organization’s ‘governing authority’; they provide a floor against which compliance programs of any industry can be benchmarked.  My industry colleagues Donna Boehme, Adam Turteltaub, and Michael Volkov refer to this as ‘Compliance 1.0’ thinking.  This social media promotional incident involving a celebrity figure highlights why the time has come for ‘Compliance 2.0’, which recognizes and pushes organizations to move beyond a minimal ‘compliance with the law’ perspective.  Michael Volkov has some suggestions on his blog for enhancing the sentencing guidelines on the Corruption, Crime and Compliance Blog. […]