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Corporate Compliance Programs
Since November 1, 1991, the date of enactment of the Federal Sentencing Guidelines, our corporate leaders are responsible for ensuring that "reasonable steps" are taken to achieve compliance with the Federal Sentencing Guidelines. At a minimum, corporate leaders should ensure that appropriate monitoring and auditing systems are in place and reasonably designed to detect criminal conduct by its employees and other agents. Secondly, corporate leaders should ensure that a system is in place to publicize a reporting system, whereby employees and other agents can report criminal conduct by others within the organization, without fear of retribution.
Are you in compliance with these guidelines?
Can you describe your monitoring systems to detect
criminal misconduct?
Do you have a reporting system in place?
What assurance do your employees have that they will not face
retribution for reporting misconduct?
Take the time to consult with The Whall Group
professionals to ensure that you are not subject to exposure. The
Sentencing Commission has stated that an effective compliance program
(meeting the litmus test for benchmarks) can diminish (downward
departure) the culpability factor in the Guidelines computation. In
today's climate, it is not just the corporation that is exposed to
litigious action and sanctions. As a corporate officer, you also face the
same sanctions, if complacency is evident. Protect your corporation and
yourself by confidentially consulting with The Whall Group
professionals. Be proactive, rather than reactive.
Seven "Minimum" Steps Identified by the Sentencing Commission | Benchmarks