On Monday, November 1, 2004, the U.S. Sentencing Commission's revised federal sentencing guidelines became effective, requiring directors and executives to "take an active leadership role for the content and operation of compliance and ethics programs."

Promulgated in 1987 and effective since 1991, the guidelines outline the elements of a corporate compliance program, creating a sentencing credit for organizations that put in place "effective programs to prevent and detect violations of law."

Earlier this year, an "Ad Hoc Advisory Group" that was established to help redefine such corporate compliance programs released its recommendations for changes to the guidelines. Those ...