The modern era of compliance and ethics at ten years old

This week will see the tenth anniversary of the advent of the revised Federal Sentencing Guidelines for Organizations – the most influential set of official C&E-program-related expectations ever issued. More than any other legal development,  these revisions – which went into effect on November 1, 2004 – made possible the work that C&E professionals do.

In the latest issue of the SCCE’s Compliance and Ethics Professional magazine (see page 2 of this PDF) I try to sum up in a mere 400 words what the legacy to date of the Guidelines is. (My emphasis in this piece –  being a “compliance guy” – is on the empty part of the glass, but perhaps this is unfair. Indeed, by any measure, the revised Guidelines have had more of an impact in their first decade than did the Sherman Act – which can be viewed as the federal government’s first compliance law – in its first ten years of existence.)

For those with more of an appetite (and budget) for this topic, you might check out the just-published 2014 edition of this 1400-page treatise on the Guidelines which I edited with Joe Murphy, who is the one true founder of our profession (and my one true mentor).

I look forward to watching C&E program law continue to develop – particularly outside the U.S. – and hopefully live up to the full promise of the standards issued a decade ago.


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