F. Hodge O'Neal Corporate and Securities Law Symposium

Some Practical Considerations in Developing Effective Compliance Programs: A Framework for Meeting the Requirements of the Sentencing Guidelines

Authors: Dan K. Webb (Winston & Strawn LLP) , Steven F. Molo (Winston & Strawn LLP)

Abstract

This Article discusses the advantages and disadvantages of implementing an effective compliance program. It then discusses the specific elements that the Guidelines require for a sentencing court to find a compliance program effective and thus entitled to credit as a mitigating factor in the sentencing process. Finally, the Article sets forth a basic framework for establishing a compliance program that will satisfy the Guidelines' requirements.

Keywords: Criminal liability of juristic persons, Sentencing guidelines (Criminal procedure)

How to Cite: Webb, D. & Molo, S. (1993) “Some Practical Considerations in Developing Effective Compliance Programs: A Framework for Meeting the Requirements of the Sentencing Guidelines”, Washington University Law Review. 71(2).