Proposed Amendments to U.S. Sentencing Guidelines: Revisions Dovetail With Timing of U.K. Bribery Act and Impact the Effectiveness of Compliance Programs

The importance of corporate ethics and compliance programs has been emphasized by U.S. law enforcement authorities since the early 1990s, when the U.S. Sentencing Commission first issued Guidelines offering credit in the form of reduced penalties to companies that work diligently to prevent misconduct.  These Guidelines have served as the principal framework for assessing corporate misconduct for multiple U.S. enforcement agencies, including the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”). 

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