The U.S. Sentencing Commission is mulling possible changes to its Federal Sentencing Guidelines that could change the expectations for “effective” corporate compliance programs generally, and for the chief compliance officer in particular.

The Guidelines, first enacted in 1991 and last revised in 2004, spell out 10 points that define an effective compliance program. They have become the de facto template for how corporate compliance programs are structured and managed, so that corporations can demonstrate to prosecutors that they have made a good-faith effort at preventing corruption, and consequently seek kinder treatment should the company be under investigation.

“The guidelines have significant ...