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“Effective” Compliance Programs: The Sentencing Commission Speaks – Again

On April 13, 2004, the U.S. Sentencing Commission announced its new guidelines for obtaining mitigation credit for an effective compliance program. The new Guidelines go to Congress on May 1 and become effective November 1, 2004, absent Congressional intervention. The Introductory Commentary makes clear that the Commission intends its amendments to have a sweeping impact […]

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