The U.S. Sentencing Commission has approved changes to the Federal Sentencing Guidelines aimed at bolstering the strength and independence of the chief compliance officer, although it dropped controversial proposals to change the language about independent monitors and document retention.
The Commission approved the changes on April 7, but published the text of the new provisions only last week. The guidelines dictate what corporations should do to have an “effective” ethics and compliance program in the eyes of the law, which in turn should make the company eligible for more cooperation credit when it is under investigation. As such, the guidelines have evolved into a de facto blueprint for how companies should structure their compliance function.
