Joseph Murphy, Feb 14, 2012
Compliance programs today are generally recognized as key weapons in the fight against corporate crime and wrongdoing. When the U.S. Sentencing Guidelines (“USSG”) in 1991 instituted a carrot and stick approach to promote programs, and set out a rigorous definition, this triggered a strong focus on making such programs effective. The understanding of such programs shifted dramatically, from mere codes and lawyer lectures, to requiring the use of a full ran
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